G.R. No. 116237. May 15, 1996.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FE ARCILLA y CORNEJO, accused-appellant.

FACTS

Accused-appellant Fe Arcilla was charged with parricide for stabbing her husband, Antonio Arcilla, on May 1, 1992, in Daraga, Albay. The prosecution evidence, primarily from eyewitness Lilia Lipio (Antonio’s mistress), established that Fe, after learning of her husband’s long-standing infidelity, confronted him at Lilia’s residence during a feast. A heated argument ensued in a bedroom. At its height, Fe drew a fan knife from her bag and stabbed Antonio in the chest. As he embraced her, Lilia intervened, and Fe managed to deliver a second stab wound to his thigh before fleeing. Antonio died from the injuries.
The accused presented a different account, claiming self-defense. She testified that during the confrontation, Antonio pushed her, and she saw a knife in a cabinet. She claimed she warned him, but they grappled for the weapon. She asserted that Antonio, while trying to direct the knife towards her, was accidentally stabbed twice during her struggle to free herself. The trial court convicted Fe Arcilla of parricide, sentencing her to reclusion perpetua and ordering her to pay damages.

ISSUE

The core issue is whether the trial court erred in convicting the accused of parricide, thereby rejecting her claims of accidental killing and self-defense.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment crediting the clear, consistent, and categorical testimony of eyewitness Lilia Lipio over the accused’s version. The physical evidence, particularly the location and nature of the wounds (a fatal chest stab and a thigh wound), contradicted the accused’s narrative of a accidental stabbing during a mutual struggle. The Court found her claim that she twisted her body in a manner that caused the knife to pierce the victim’s chest to be incredible and contrary to the natural course of human events.
Furthermore, the Court rejected the plea of self-defense. The evidence showed it was the accused who provoked the altercation by slapping the victim in public. Even assuming an initial aggression by the victim, there was no reasonable necessity for the accused to employ a lethal weapon, as the incident occurred in a house full of people who could have rendered assistance. The mitigating circumstance of voluntary surrender was deemed inconsequential, as reclusion perpetua remains an indivisible penalty. The penalty was thus affirmed as reclusion perpetua.