G.R. No. L-23694 October 30, 1969
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOLORES BRITOS AGLIBUT, accused-appellant.

FACTS

On the night of November 22, 1961, Telesforo Aglibut was found dead in his yard in Namalangan Santa, Ilocos Sur, with multiple stab wounds. Initial investigation pointed to Saturnino de Peralta as the sole perpetrator, based on statements from the victim’s wife, Dolores Aglibut (the appellant), and their daughter, Mary Lou. Peralta was charged with murder. Three days later, Peralta confessed in a sworn statement that he and Dolores Aglibut jointly killed her husband, claiming they had been paramours for over five years. Consequently, a complaint for parricide was filed against Dolores. At the trial, Peralta testified that on the night of the killing, he and Dolores had a tryst in her house while her husband was out fishing. When Telesforo returned and found them together, he became angry and began beating Dolores with a club. Dolores then grabbed a bolo and struck her husband. As Telesforo continued the assault, Dolores called for Peralta’s help. Peralta unsheathed his bolo and joined in hacking the victim. The wounded Telesforo fled downstairs but was followed and further attacked by Dolores until he fell dead by the gate. The autopsy report detailed twenty-four wounds on the victim, some of which were heavy blows indicative of a strong assailant, and others were lighter cuts. The trial court found Dolores Aglibut guilty of parricide.

ISSUE

Whether the trial court erred in finding that the accused-appellant, Dolores Aglibut, actively participated in the killing of her husband based on the testimony of Saturnino de Peralta, thereby convicting her of parricide.

RULING

The Supreme Court affirmed the trial court’s decision. The trial court’s finding that the accused actively participated in the killing was fully supported by the evidence. The nature and location of the victim’s multiple wounds indicated they were inflicted by at least two assailants. The Court upheld the credibility of Saturnino de Peralta’s testimony, which was corroborated by physical evidence, including the necropsy report and a sketch of the crime scene showing bloodstains from the house to the yard. The appellant’s alternative claim of self-defense was rejected for lack of evidence of unlawful aggression on the part of the deceased husband and for failure to prove the essential elements of self-defense. The Court also found the appellant’s and her daughter’s versions of events to be untenable and inconsistent. The judgment of conviction for parricide under Article 246 of the Revised Penal Code was affirmed, with the modification that the indemnity to the heirs of the deceased was increased to P12,000.00.