G.R. No. 247603, May 05, 2021
People of the Philippines, Plaintiff-Appellee, vs. Benjamin Padilla y Espiritu, Accused-Appellant.

FACTS

Accused-appellant Benjamin Padilla y Espiritu was charged with Parricide for the killing of his wife, Marcelina Tabares Padilla, on November 3, 2014. The prosecution presented circumstantial evidence, including the testimony of Barangay Captain Arnulfo Martin, who stated that after being informed of a quarrel at the accused’s house, he proceeded there and encountered the accused, who stated, “Hindi ko alam ang nangyari pare[,] napatay ko yata ang aking asawa.” The victim’s lifeless body was found inside the house, and the autopsy report indicated she died from heart and lung injuries secondary to stab and hacking wounds. Initially, the accused testified that he found his wife already bloodied upon arriving home. Later, after the defense case was reopened, he testified that he arrived home drunk, his wife confessed to having an affair, and in a fury, he got a knife and might have killed her. The Regional Trial Court (RTC) convicted him of parricide based on circumstantial evidence and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the conviction with modifications to the damages awarded. The accused appealed, arguing the RTC and CA failed to appreciate the mitigating circumstances of passion or obfuscation and intoxication.

ISSUE

Whether the trial court and the Court of Appeals erred in failing to appreciate the mitigating circumstances of passion or obfuscation and intoxication in imposing the correct penalty.

RULING

The Supreme Court denied the appeal and affirmed the CA decision. The Court found no reason to deviate from the factual findings of the RTC and CA, which held that the accused failed to establish the mitigating circumstances of passion or obfuscation and intoxication. The CA ruled that the accused did not provide clear and convincing proof of his wife’s confession of infidelity to produce passion and obfuscation. Regarding intoxication, the accused failed to prove he was in such a state as to blur his reason, noting he was able to keenly observe details upon arriving home. The Court further held that even if these mitigating circumstances were not considered, the presence of the mitigating circumstance of voluntary surrender, with no aggravating circumstance, still warrants the penalty of reclusion perpetua under Article 63 of the Revised Penal Code. The Court adopted the CA’s awards of P75,000.00 each as civil indemnity, moral damages, and exemplary damages, with interest at 6% per annum from finality until full payment.