G.R. No. 140206, June 21, 2001
People of the Philippines, plaintiff-appellee, vs. Rodolfo Matyaong, accused-appellant.

FACTS

Accused-appellant Rodolfo Matyaong was charged with parricide for allegedly hitting his wife, Rufina Matyaong, with a piece of mangrove wood (bakawan) on December 27, 1995, in Brgy. Latud, Rizal, Palawan, causing multiple contusions and hematomas that led to her death on December 29, 1995. Upon arraignment, he pleaded not guilty. The prosecution presented four witnesses: (1) Rodolfo Matyaong, Jr., the couple’s ten-year-old son, who testified that he witnessed his father beat his mother with the wood after suspecting the letter she was reading was from another man, causing her to lose consciousness; (2) Wilfredo Tablazon, a barangay kagawad, who testified that he helped the injured Rufina, who was hiding and pleading for help, and later heard accused-appellant tell his wife at the health center, “Hindi rin mangyari yan kung hindi mo kasalanan”; (3) Roberta Paz, the victim’s mother, who saw her daughter’s bruises and was told Rufina was mauled by accused-appellant; and (4) Sgt. Almirante Caburnay, a marine assigned as a first aider, who treated Rufina at the Canipaan health center, observed bruises and hematoma on her left arm and back, administered dextrose and antibiotics for diarrhea and vomiting, and noted she died the following morning. The defense claimed Rufina died from dehydration due to diarrhea and vomiting after eating fish, presenting accused-appellant’s testimony that he cared for her at the health center and Vilma Apostol’s testimony that Rufina was in serious condition from vomiting and diarrhea. The trial court convicted accused-appellant of parricide, sentencing him to reclusion perpetua and ordering civil indemnity, finding that although he may not have intended to kill, the death was a direct consequence of his felonious act under Article 4 of the Revised Penal Code.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellant’s act of beating his wife caused her death, thereby establishing the corpus delicti for parricide.

RULING

The Supreme Court ACQUITTED accused-appellant of parricide. The Court held that while the prosecution established that accused-appellant beat his wife (based on the credible, unrebutted testimony of his son), it failed to prove the corpus delicti—specifically, the causal link between the beatings and her death. No medical certificate, autopsy report, or expert testimony was presented to demonstrate that the injuries inflicted were the direct and immediate cause of death. The evidence showed Rufina was suffering from severe diarrhea and vomiting, which were prevalent in the locality, and she was treated for dehydration. The prosecution did not rule out the possibility that death resulted from natural causes (illness) rather than the beating. Without conclusive proof that the criminal act caused the death, the element of parricide that the accused killed the deceased was not established beyond reasonable doubt. However, the Court found accused-appellant liable for slight physical injuries under Article 266(3) of the Revised Penal Code for ill-treating his wife. Considering his detention period already exceeded the penalty for that crime (arresto menor), no further punishment was imposed.