G.R. No. L-36282 December 10, 1976
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. COSME MONLEON, accused-appellant.

FACTS

Cosme Monleon, an illiterate farmer, was convicted of parricide for the death of his wife, Concordia Bongo. On June 1, 1970, Monleon returned home intoxicated from drinking tuba. He discovered his carabao had not been adequately fed by their son, Marciano. Enraged, he attempted to whip the boy, but his wife intervened. A violent quarrel ensued, during which Monleon assaulted Concordia by choking her, bashing her head against a post, and kicking her in the abdomen. She was pulled away by their son, Felicisimo. The following morning, Concordia vomited blood and died. The cause of death was certified as “acute abdomen.”
The prosecution established the corpus delicti through the testimonies of witnesses Clemencia Bongo-Monleon and Epifania Bongo, who detailed the assault. Monleon also executed an extrajudicial confession admitting to the assault. An NBI medico-legal officer who exhumed the body found internal hemorrhages consistent with external violence. Monleon denied the violence, claiming a mere verbal quarrel and alleging his confession was coerced and the witnesses were motivated by a land dispute.

ISSUE

Whether the trial court erred in convicting Cosme Monleon of parricide based on the evidence presented.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the sufficiency of evidence establishing both the corpus delicti and Monleon’s criminal liability. The testimonies of the prosecution witnesses, corroborated by the medical findings of trauma, conclusively proved that Concordia Bongo died as a result of a felonious assault. Monleon’s extrajudicial confession was deemed admissible and voluntary, and it was corroborated by this independent evidence of the corpus delicti, as required by the Rules of Court.
The Court applied Article 4 of the Revised Penal Code, which holds a person criminally liable for a felony committed, even if the resulting act differs from what was intended. Monleon’s acts of physical violence were the proximate cause of his wife’s death, constituting parricide. However, the Court agreed with the Solicitor General’s assessment that mitigating circumstances were present, namely lack of intent to commit so grave a wrong and intoxication that was not habitual. While these did not alter the prescribed penalty of reclusion perpetua under the law, the Court found its strict application excessive under the circumstances, noting the death may have been hastened by lack of medical care. Consequently, while affirming the judgment, the Supreme Court endorsed the Solicitor General’s recommendation for executive clemency, ordering that a copy of the decision be furnished to the Chief Executive for possible commutation of the penalty.