G.R. No. 44409 February 21, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IGNACIO GONZALES, JR. y OLIVEROS, defendant-appellant.

FACTS

The appellant, Ignacio Gonzales, Jr., was convicted of parricide for the death of his wife, Gloria Balleza Gonzales. The prosecution established that on the morning of February 11, 1974, in their home in Sagay, Negros Occidental, the appellant pulled his wife into their bedroom. Their niece, May Balleza, who was in the house, heard the victim cry for help and ask, “why are you going to kill me?” before hearing sounds of a commotion. May fled and later observed blood dripping from the floor above and saw her aunt’s body. A neighbor, Wilfredo Gregorio, also heard Gloria shouting for help and later saw the appellant’s house on fire. After the fire, Gloria’s severely burned cadaver was found inside.
An autopsy conducted by Dr. Pedro de Ocampo revealed two stab wounds on the victim’s chest, which penetrated her lungs and major blood vessels. The cause of death was shock secondary to severe hemorrhage. The appellant was apprehended later that day. Prosecution witnesses, police officers Montebon and Canal, testified that upon arrest, the appellant surrendered a knife and admitted to killing his wife out of jealousy, claiming she had a paramour.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that the appellant committed parricide by deliberately killing his wife.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the sufficiency and credibility of the prosecution’s evidence to establish the appellant’s guilt. The Court found the testimonies of eyewitness May Balleza and neighbor Wilfredo Gregorio credible and consistent, detailing the events leading to the crime. Their alleged motives for bias, as claimed by the defense, were deemed insufficient to discredit their accounts.
Crucially, the Court upheld the autopsy findings of Dr. de Ocampo over a defense expert’s contrary opinion. Dr. de Ocampo, who physically examined the body, confirmed the presence of fatal stab wounds on body parts not completely charred. This evidence directly refuted any theory of an accidental death from the fire alone. Furthermore, the appellant’s own extrajudicial admission to the arresting officers—that he killed his wife due to jealousy—constituted a direct acknowledgment of culpability. The trial court correctly appreciated the mitigating circumstance of passion and obfuscation based on this admission. The Court concluded that the prosecution successfully proved the appellant willfully caused his wife’s death, either by stabbing, burning, or both. The decision was affirmed with a modification increasing the civil indemnity.