G.R. No. 19921; July 30, 1923
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. BLAS SOLINDAYAO, defendant-appellant.

FACTS

The appellant, Blas Solindayao, was charged with parricide for killing his wife, Filomena Eyano, with a bolo. He admitted the killing but claimed he did so because he caught his wife and Clemente Omayon in the act of adultery in his house. The prosecution’s main witness, Magna Eyano (sister of the deceased and wife of Omayon), testified that the quarrel began over a missing package of nails and that the appellant killed his wife in a fit of anger. After the defense rested, the prosecution presented Clemente Omayon, who denied being at the appellant’s house and claimed he was at the house of the barrio lieutenant, Pantaleon Dalagdon, at the time. The defense then sought to present Dalagdon in rebuttal to testify that Omayon was not at his house but was seen coming from the appellant’s house. The trial court refused to allow Dalagdon’s testimony. The appellant was convicted of parricide and sentenced to cadena perpetua.

ISSUE

Whether the trial court erred in refusing to allow the defense to present the testimony of Pantaleon Dalagdon in rebuttal, and whether the evidence was sufficient to convict the appellant of parricide beyond a reasonable doubt.

RULING

Yes, the trial court erred in excluding the rebuttal testimony. The testimony of Pantaleon Dalagdon, as the barrio lieutenant and a disinterested witness, would have directly contradicted Clemente Omayon’s alibi and strongly corroborated the appellant’s claim of having caught Omayon with his wife. This exclusion was prejudicial error. Considering the appellant’s straightforward testimony, the excluded evidence, and the prosecution’s reliance on a single eyewitness (who was the sister of the deceased and wife of the alleged paramour), the evidence was not sufficient to prove parricide beyond a reasonable doubt. The appellant is entitled to the benefit of the doubt. The killing, under the circumstances testified to by the appellant, falls under Article 423 of the Penal Code (killing a spouse surprised in the act of adultery). The conviction for parricide is reversed. The appellant is sentenced to destierro for two years, four months, and one day.