G.R. No. L-49149 October 23, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GREGORIO TAYLARAN alias “Goring”, defendant-appellant.

FACTS

The prosecution’s evidence established that on November 5, 1976, appellant Gregorio Taylaran went to the house of his grandmother-in-law, Ofremia Atup, a local quack doctor, seeking treatment for a snake bite. Once inside and while being treated, Taylaran suddenly drew a small bolo and stabbed the deceased several times, causing her death. He then proceeded to the house of the victim’s son but was refused entry. Taylaran subsequently surrendered to a policeman at the municipal hall, stating he killed the victim because she had promised to kill him through “barang” or witchcraft. This statement was corroborated by the victim’s daughter, Juanita Busalla.
The defense presented a starkly different version. Taylaran claimed that while he was using his bolo to open his snake bite wound as instructed by the deceased, he accidentally extinguished a kerosene lamp. As the victim bent down to relight it, he allegedly raised his hand holding the bolo, and its point accidentally hit her chest, resulting in a fatal wound. He asserted this was a single, accidental strike, after which he asked for forgiveness and fled.

ISSUE

Whether the killing of Ofremia Atup was committed with deliberate intent, constituting murder, or was merely accidental as claimed by the appellant.

RULING

The Supreme Court affirmed the conviction, rejecting the defense of accidental killing. The Court found the appellant’s version inherently incredible and contrary to the physical evidence. The trial court correctly gave more weight to the prosecution’s evidence. The Court’s legal logic centered on the inherent improbability of the defense story. The medical fact that the victim sustained multiple wounds on different parts of her body completely negated the claim of a single, accidental blow. A single accidental stroke could not have inflicted all the wounds. The locations of the wounds precluded such a possibility. The Court reasoned that if the first wound were truly accidental, instinct would have compelled the appellant to drop the bolo immediately to aid the victim, not continue holding it to inflict further injuries. The infliction of repeated blows was indicative of deliberate intent to kill.
Furthermore, the appellant’s post-killing conduct and admissions bolstered the finding of deliberate killing. His statement upon surrender—that he killed the victim because she threatened him with witchcraft—was a clear admission of motive and intent. This admission was properly testified to by the policeman and corroborated by the victim’s daughter. The Court clarified that this testimony was admissible not as part of the res gestae but simply as a witness’s account of a statement they personally heard, with no constitutional violation as it was a voluntary explanation for surrendering. The fact that the victim’s family refused him entry to their house immediately after the incident suggested he appeared angry and dangerous, not remorseful as one would expect from an accidental killer. Since the appellant admitted the killing, the burden shifted to him to prove the exempting circumstance of accident by clear and convincing evidence, which he failed to do. The conviction for murder was thus upheld.