GR 107801; (March, 1997) (Digest)
G.R. No. 107801 March 26, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROSARIA V. IGNACIO, accused-appellant.
FACTS
Rosaria V. Ignacio was charged with parricide for fatally hitting her husband, Juan Ignacio, with a wooden club (palo-palo) on February 10, 1992, in Rodriguez, Rizal. The prosecution’s evidence, primarily from Rosaria’s daughter Milagros, established that after a quarrel, Rosaria struck Juan on the head as he turned to get a bolo. Rosaria surrendered to the police. Juan died the next day from traumatic head injuries.
In her defense, Rosaria admitted hitting Juan but claimed self-defense. She testified that Juan, drunk and armed with a bolo, approached her while she was resting. She asserted she acted out of fear, hitting him once. She did not present other witnesses. The trial court convicted her of parricide, sentencing her to reclusion perpetua.
ISSUE
The core issues were whether Rosaria acted in self-defense and whether the crime committed was parricide or homicide.
RULING
The Supreme Court affirmed the conviction for parricide but rejected the plea of self-defense. For self-defense to prosper, unlawful aggression by the victim is indispensable. The Court found Rosaria’s claim of unlawful aggression unconvincing. Her testimony that Juan was armed and approaching her was uncorroborated and inconsistent with the physical evidence and the prosecution witness’s account, which suggested the initial aggression had ceased when Juan turned away. Without clear proof of an imminent attack, self-defense fails.
Regarding the nature of the crime, the Court upheld the parricide conviction. Rosaria argued the prosecution failed to prove a valid marriage. The Court ruled that the marriage was sufficiently established. Testimonies from both the victim’s son and Rosaria’s daughter, along with Rosaria’s own admission of marriage before a judge, created a strong presumption of marriage under the law. The Court applied the principle semper praesumitur matrimonio—persons living together as husband and wife are presumed legally married. The mitigating circumstance of voluntary surrender was properly appreciated, warranting the penalty of reclusion perpetua. The indemnity was increased to P50,000.00.