G.R. Nos. L-35584-85 February 13, 1982
The People of the Philippines, plaintiff-appellee, vs. Alfredo Arroyo y Digoma, defendant-appellant.

FACTS

The appellant, Alfredo Arroyo, was charged with Parricide and Illegal Possession of Firearms for the death of his wife, Milagros Mayuyu, by a gunshot wound. The cases were jointly tried in the Court of First Instance of Quezon City. The prosecution established that on October 7, 1971, a gunshot was heard from the couple’s room. The victim’s sister found Milagros wounded and being carried by Arroyo. The victim later died from the gunshot wound to her head. During police investigation, Arroyo voluntarily executed a sworn confession admitting he owned an unlicensed .22 caliber revolver and that he shot his wife in a fit of anger due to her persistent gambling.
At trial, Arroyo repudiated his confession, claiming the shooting was accidental. He testified that a struggle over the firearm, which his wife had acquired from a pawn, caused it to discharge. The trial court convicted him on both charges, sentencing him to Reclusion Perpetua for Parricide and one year imprisonment plus a fine for Illegal Possession. Arroyo appealed the decision.

ISSUE

The core issues were whether the prosecution proved Arroyo’s guilt for Parricide beyond reasonable doubt and whether the penalty for Illegal Possession was correctly imposed.

RULING

The Supreme Court affirmed the convictions but modified the penalty for illegal possession. The Court found the appellant’s confession, Exhibit “H”, to be admissible and credible. It was given voluntarily, without any claim of coercion or misunderstanding by Arroyo during the trial. This confession contained a direct admission of shooting his wife out of anger, providing clear motive. In contrast, his alternative claim of an accidental shooting during a struggle was deemed unconvincing. The Court noted that the necropsy report, which found the victim’s hands negative for gunpowder, directly contradicted the narrative of a close-range grapple for the weapon.
The legal logic rests on the principle that a voluntary extrajudicial confession, corroborated by other evidence like the physical findings and witness testimony, constitutes strong proof of guilt. Arroyo failed to meet the burden of proving his defense of accident by clear and convincing evidence. Regarding the illegal possession charge, the Court applied the correct penalty under Republic Act No. 4 , which mandates a minimum imprisonment of one year and one day for possession of a .22 caliber firearm. Thus, the trial court’s penalty of exactly one year was erroneous and was modified accordingly. The decision was affirmed in all other respects.