G.R. No. L-13982. January 28, 1961.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ESTANISLAO MANGAHAS, defendant-appellant.

FACTS

The prosecution established that Estanislao Mangahas was married to Virginia Coderes. On the evening of May 8, 1956, neighbors discovered Virginia dead inside their home. Mangahas initially claimed he found his wife having hanged herself from a beam. The assistant barrio lieutenant noted the hanging rope’s end appeared cut. The cadaver was subjected to a post-mortem examination, which listed the cause of death as asphyxia by hanging but also documented multiple contusions and abrasions on the body, including hematomas on the scalp.
Subsequently, on May 14, Mangahas executed a detailed confession. He admitted that after a quarrel where his wife insulted him, he struck her. Upon leaving and returning, he found her armed with a bolo. A struggle ensued, during which he hit her on the head with a piece of bamboo. Seeing she was still breathing, he hanged her with a rope to make her death appear a suicide, later confessing due to a troubled conscience. At trial, the defense attempted to argue suicide, suggesting the injuries resulted from the hanging process against a bamboo wall.

ISSUE

The core issue is whether the evidence, particularly the appellant’s confession and the physical evidence, suffices to prove his guilt for parricide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction for parricide but modified the appreciation of mitigating circumstances. The Court found the confession, Exhibit “B”, credible and corroborated by the physical evidence. The multiple contusions, especially the hematoma on the scalp, were inconsistent with a simple suicide by hanging but aligned with Mangahas’s account of a violent physical struggle and a blow to the head. The Court rejected the defense’s theory that these injuries were caused by friction during hanging against a split bamboo wall, deeming it improbable. The initial false suicide story and the conduct of the barrio lieutenant, who was Mangahas’s brother-in-law but deferred the investigation, further indicated consciousness of guilt.
Regarding penalties, the trial court found two mitigating circumstances: obfuscation and lack of intent to commit so grave a wrong. The Supreme Court sustained only obfuscation, arising from the heated quarrel. It ruled that the act of hanging the victim, done to conceal the crime, could not constitute lack of intent for a grave wrong; it was part of the criminal act itself. Thus, with one mitigating circumstance and no aggravating circumstances, the penalty of reclusion perpetua imposed by the lower court was affirmed.