G.R. No. L-63154 June 19, 1984
The People of the Philippines, plaintiff-appellee, vs. Sukarno Mawallil y Kars, defendant-appellant.

FACTS

Sukarno Mawallil was convicted of parricide for the killing of his wife, Sophia Sera. The prosecution presented circumstantial evidence showing a history of Sukarno’s jealousy, frequent quarrels, and threats against Sophia with a Batangas knife. On the evening of November 23, 1980, Sukarno took Sophia out to dinner. Later that night, security guards found Sophia’s body with multiple fatal stab wounds near a university campus. Sukarno, found shirtless at the scene, claimed they had been held up. The police recovered a bloodstained Batangas knife and Sukarno’s watch near the body. His post-crime behavior was deemed suspicious: he did not mourn with the family, avoided the funeral, and later threatened his in-laws in court.
Sukarno presented an alternative story of being robbed and assaulted by four men, claiming he was unconscious during the attack. He also challenged the validity of his marriage to Sophia, arguing she was previously married under Muslim law and their subsequent union was not valid under the Revised Penal Code, thus negating the element of parricide.

ISSUE

The primary issue is whether the circumstantial evidence sufficiently proves Sukarno’s guilt for parricide beyond reasonable doubt. A secondary issue is the validity of the accused’s marriage to the victim under Muslim law for the purpose of establishing parricide.

RULING

The Supreme Court affirmed the conviction. The circumstantial evidence—comprising motive (jealousy), possession of the murder weapon, his presence and shirtless condition at the crime scene, his implausible holdup story, and his unnatural post-crime conduct—formed an unbroken chain leading to the reasonable conclusion that Sukarno was the perpetrator. The Court found his testimony fabricated and inconsistent.
Regarding the marriage’s validity, the Court ruled it was legally established. Sophia’s prior divorce from her first husband was validly effected under Muslim customs as authorized by Presidential Decree No. 793. Her subsequent marriage to Sukarno was likewise solemnized in accordance with Muslim rites, which he admitted. The presumption of marriage validity applies. Therefore, the killing of a spouse constitutes parricide under Article 246 of the Revised Penal Code. The Court modified the penalty, appreciating the mitigating circumstance of voluntary surrender, and imposed reclusion perpetua with an increased indemnity.