PEOPLE v. MANUEL MACAL Y BOLASCO
PEOPLE v. MANUEL MACAL Y BOLASCO
PEOPLE v. MANUEL MACAL Y BOLASCO
211062, 2016-01-13
Facts:
Angeles, the mother of Auria, narrated that Auria and the accused-appellant got
married in March 2000 and that out of their union, they begot two (2) children.
Angeles claimed that, at the time of the incident, they were all living together in
a house located in V & G Subdivision, Tacloban City. The said house was
entrusted to Angeles by her brother, Quirino Ragub, who was then residing in
Canada.Angeles testified that at around 1:20 in the morning of February 12,
2003, she, her children Catherine, Jessica, Auria and Arvin were walking home
after playing bingo at a local peryahan. Some friends tagged along with them so
that they could all feast on the leftover food prepared for the fiesta that was
celebrated the previous day. Along the way, Angeles and her group met Auria's
husband, the accused appellant. The latter joined them in walking back to their
house.When they arrived at the house, the group proceeded to the living room
except for Auria and the accused-appellant who went straight to their bedroom,
about four (4) meters away from the living room. Shortly thereafter, Angeles
heard her daughter Auria shouting, "mother help me I am going to be killed."[6]
Upon hearing Auria's plea for help, Angeles and the rest of her companions
raced towards the bedroom but they found the door of the room locked. Arvin
kicked open the door of the bedroom and there they all saw a bloodied Auria on
one side of the room. Next to Auria was the accused-appellant who was then
trying to stab himself with the use of an improvised bladed weapon (belt
buckle). Auria was immediately taken to a hospital, on board a vehicle owned by
a neighbor, but was pronounced dead on arrival. Angeles declared that the
accused-appellant jumped over the fence and managed to escape before the
policemen could reach the crime scene.
Issues:
The principal issue before the Court is whether the court a quo erred in finding
the accused-appellant guilty beyond reasonable doubt of the crime of parricide.
Ruling:
All the Essential Elements of Parricide Duly Established and Proven by the
ProsecutionParricide is committed when: (1) a person is killed; (2) the deceased
is killed by the accused; (3) the deceased is the father, mother, or child, whether
legitimate or illegitimate, or a legitimate other ascendants or other descendants,
or the legitimate spouse of the accused.[13]Among the three requisites, the
relationship between the offender and the victim is the most crucial.[14] This
relationship is what actually distinguishes the crime of parricide from homicide.
[15] In parricide involving spouses, the best proof of the relationship between
the offender and victim is their marriage certificate.[16] Oral evidence may also
be considered in proving the relationship between the two as long as such proof
is not contested.[17]In this case, the spousal relationship between Auria and the
accused-appellant is beyond dispute. As previously stated, the defense already
admitted that Auria was the legitimate wife of the accused-appellant during the
pre-trial conference. Such admission was even reiterated by the accused-
appellant in the course of trial of the case. Nevertheless, the prosecution
produced a copy of the couple's marriage certificate which the defense admitted
to be a genuine and faithful reproduction of the original.[18] Hence, the key
element that qualifies the killing to parricide was satisfactorily demonstrated in
this case.Just like the marital relationship between Auria and the accused-
appellant, the fact of Auria's death is incontestable. Witnesses, from both the
prosecution and defense, were in agreement that Auria expired on February 12,
2003. As additional proof of her demise, the prosecution presented Auria's
Certificate of Death which was admitted by the RTC and the defense did not
object to its admissibility.
Principles: