G.R. No. 211062, January 13, 2016.
People of the Philippines, Plaintiff-Appellee, vs. Manuel Macal y Bolasco, Accused-Appellant.

FACTS

Accused-appellant Manuel Macal was charged with parricide for the killing of his wife, Auria Ytac Macal, on February 12, 2003, in Tacloban City. The Information alleged he stabbed her with an improvised bladed weapon and a kitchen knife inside their bedroom. Upon arraignment, he pleaded not guilty. The prosecution presented witnesses Angeles Ytac (the victim’s mother) and Erwin Silvano. They testified that after returning home from a peryahan in the early morning, the accused-appellant and the victim went to their bedroom. Shortly after, the victim was heard shouting for help. Upon forcing the door open, they saw the victim bloodied and the accused-appellant trying to stab himself with a belt buckle. The victim was pronounced dead on arrival at the hospital from a stab wound. The defense presented the accused-appellant, who admitted stabbing his wife but claimed it was accidental. He testified that upon arriving home, he was warned his wife was in the bedroom with another man. He kicked the door open, saw them, went out to get a knife, and attempted to stab the man, but his wife shielded the man and was hit instead. After the man fled, the accused-appellant wounded himself and went to the hospital. Witness Benito Billota corroborated part of this story, and Nerissa Alcantara presented hospital records of the accused-appellant’s injuries. The Regional Trial Court convicted him of parricide, sentencing him to reclusion perpetua and ordering him to pay civil indemnity and moral damages. The Court of Appeals affirmed the conviction with modifications to the damages.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of parricide.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modifications to the awarded damages. The Court held that all the elements of parricide were proven beyond reasonable doubt: (1) the victim was the spouse of the accused, a fact stipulated during pre-trial; (2) the accused killed the victim; and (3) the killing was qualified as parricide. The accused-appellant’s claim of accidental stabbing was rejected. The Court found his story—that a stranger was present, shielded by the victim, and then escaped without anyone else seeing him—to be contrary to human experience and unbelievable, especially given the immediate presence of other people in the house. The credible and consistent testimonies of the prosecution eyewitnesses, who saw the accused-appellant with the victim immediately after hearing her cries for help, established his guilt. The claim of accident is a weak defense that cannot prevail over positive identification. The penalty of reclusion perpetua was affirmed as the proper penalty for parricide absent any aggravating or mitigating circumstances. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to Php75,000.00 each, and awarding temperate damages of Php50,000.00 in lieu of actual damages, plus interest on all damages at 6% per annum from finality of judgment until fully paid.