G.R. No. L-4429; April 18, 1952
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PAULINO BELARMINO, defendant-appellant.

FACTS

Paulino Belarmino was convicted of parricide for killing his wife, Eusebia Pavia, and sentenced to reclusion perpetua. The couple, married around 1940-1941, had four children. They lived in Guinobatan, Albay, until 1948 when Paulino moved the family to Naga. On May 25, 1950, Eusebia died from a skull fracture and profuse hemorrhage. The defense claimed she accidentally fell from a nangka tree. The prosecution, however, proved Paulino killed her with a wooden club during a quarrel. Authorities found the tree low, the ground soft, no picked fruit, and a bloodied club. Paulino initially gave a sworn affidavit (Exhibit D) admitting the killing out of anger and jealousy, and pleaded guilty at arraignment. He later repudiated the affidavit, alleging coercion, but the trial court found it voluntary. The motive stemmed from Paulino’s belief in his wife’s infidelity, including finding her with another man in 1948 and discovering a bus ticket to Guinobatan days before the killing. During a quarrel, she suggested separation and taunted him to kill her, leading him to strike her with the club.

ISSUE

Whether the trial court erred in convicting Paulino Belarmino of parricide based on the evidence, particularly the voluntary affidavit and rejection of the accidental death theory.

RULING

The Supreme Court affirmed the conviction. It upheld the trial court’s findings that the affidavit was voluntarily given, rejecting claims of intimidation. The evidence conclusively disproved the accidental fall theory and established Paulino killed his wife with a club. The mitigating circumstance of passion and obfuscation was recognized, though irrelevant for imposing reclusion perpetua (the lesser penalty for parricide under the Penal Code), but noted it may be considered for executive clemency. No reversible error was found in the decision.