G.R. No. L-61873 October 31, 1984
The People of the Philippines, plaintiff-appellee, vs. Elias Borromeo, defendant-appellant.

FACTS

At noon on July 3, 1981, a child reported that Elias Borromeo was killing his wife, Susana Taborada-Borromeo. Relatives rushed to the couple’s hut, finding the door and windows closed. Through the bamboo slats, they saw Susana motionless on the floor beside her crying infant, with Elias lying nearby holding a bloody bolo. Police were summoned and, upon gaining entry, found Susana dead with multiple stab wounds, her intestines spilled. The police medico-legal officer documented five incised wounds and six stab wounds as the cause of death.
Elias Borromeo was charged with and convicted of parricide by the trial court, which sentenced him to reclusion perpetua. On appeal, he conceded to killing Susana but argued the crime was homicide, not parricide, claiming the absence of a valid legal marriage. He also asserted the presence of mitigating circumstances.

ISSUE

The core issue is whether the crime committed is parricide, which requires a valid marriage between the accused and the victim, or the lesser crime of homicide.

RULING

The Supreme Court affirmed the conviction for parricide. The legal logic centers on the conclusive proof of marriage. While the defense argued no marriage contract was executed, the accused himself testified under oath that he was married to Susana Taborada, specifying they were wed by a priest in a chapel. This judicial admission constitutes the best evidence of the marital union.
The Court emphasized the powerful legal presumption in favor of marriage when two persons live together as husband and wife, citing the principle that the law presumes morality and the legitimacy of family relations. This presumption stands absent clear evidence to the contrary. The lack of a registered marriage certificate does not invalidate a marriage if all essential requisites for its validity were present during its celebration. The accused’s own testimony established those requisites.
Regarding the alleged mitigating circumstances of provocation/obfuscation and voluntary surrender, the Court ruled that even assuming their presence with no aggravating circumstances, the prescribed penalty for parricide under Article 246 of the Revised Penal Code is reclusion perpetua to death. Applying the rules for a penalty composed of two indivisible penalties with mitigating and no aggravating circumstances, the lesser penalty of reclusion perpetua is still properly imposed. The decision was affirmed with an increase in the civil indemnity.