People v. Monleon
REITERATIONFacts
The Antecedents: Appellant Cosme Monleon, a forty-five-year-old illiterate farmer, imbibed copious amounts of tuba while working on June 1, 1970. Upon arriving home drunk, he inquired about their carabao being fed by their ten-year-old son, Marciano. His wife, Concordia Bongo, assured him it was fed. Upon checking and finding it inadequately fed, Monleon became furious. When he was about to whip Marciano, Concordia intervened, leading to a violent quarrel. Monleon placed himself astride his wife's chest, squeezed her neck, pressed her head against a post, and kicked her in the abdomen, stating he did not care if someone would be buried the next day. Their son, Felicisimo, intervened and stopped the assault. The following morning, Concordia vomited blood and died at eleven o'clock on June 2, 1970, due to "acute abdomen." Procedural History: Sixteen days after Concordia's death, Monleon thumbmarked a confession admitting to the assault and expressing repentance. He also orally admitted to a police lieutenant that he assaulted his wife because he was drunk and she was a nagger. An NBI medico-legal officer exhumed the body and found discolorations on the skull, neck, and ribs, indicating internal hemorrhage caused by trauma or external violence, and opined that the "acute abdomen" could have been caused by external violence. Monleon denied the assault, claiming only a verbal quarrel and alleging a boundary dispute with his wife's sister as a motive for false testimonies. The trial court convicted Monleon of parricide, sentencing him to reclusion perpetua. The Petition: Appellant Monleon appealed the trial court's decision, arguing that the court erred in giving credence to his confession, his son's affidavit, and the prosecution witnesses' testimonies, in treating alleged declarations of Concordia as part of the res gestae, and in rejecting his and his children's testimonies.
Issue(s)
Whether the extrajudicial confession of the accused is admissible and sufficient to support a conviction when corroborated by evidence of the corpus delicti. Whether the trial court erred in admitting an affidavit written in a local dialect without a corresponding translation. Whether the accused is criminally liable for the death of his wife under Article 4 of the Revised Penal Code (RPC) despite the absence of a specific intent to kill.
Ruling
The Supreme Court affirmed the trial court's judgment of conviction for parricide. The penalty of reclusion perpetua was affirmed, but a certified copy of the decision was ordered to be furnished the Chief Executive through the Secretary of Justice for possible executive clemency, considering the mitigating circumstances of lack of intent to commit so grave a wrong and intoxication.
Ratio Decidendi
On Issue 1: The Supreme Court held that the extrajudicial confession was admissible because the prosecution established it was voluntarily executed. The Court noted that the Mayor and a police lieutenant testified to the lack of coercion, and the accused failed to complain of maltreatment to the fiscal during the preliminary investigation. Minor discrepancies regarding the exact time of death and the presence of the accused at the time of death do not destroy the probative value of the confession regarding the central admission of the assault. Furthermore, under Section 3, Rule 133 of the Rules of Court, an extrajudicial confession is sufficient for conviction when corroborated by evidence of the corpus delicti, which was established by the testimonies of eyewitnesses and the medico-legal findings. On Issue 2: The Court agreed with the appellant that the trial court erred in admitting Marciano Monleon's affidavit because it was written in Cebuano without an official translation. Rule 132, Section 34 of the Rules of Court explicitly mandates that documents in an unofficial language shall not be admitted unless accompanied by a translation into English, Spanish, or the national language. Additionally, the Court found that the trial court erred in characterizing statements made by the victim to her brother-in-law as part of the 'res gestae' because the timeline and physical condition of the victim made the occurrence of such a conversation doubtful. However, these errors were deemed insufficient to exculpate the accused because the remaining evidence—specifically the eyewitness testimonies and the medical report—was sufficient to prove guilt beyond reasonable doubt. On Issue 3: The Court applied Article 4 of the Revised Penal Code (RPC), ruling that criminal liability is incurred even if the wrongful act (death) is different from what was intended (physical castigation). The physical violence inflicted by Monleon, including kicking the victim in the abdomen and bashing her head, was the proximate cause of the 'acute abdomen' and internal hemorrhages that led to her death. While the Court recognized the mitigating circumstances of lack of intent to commit so grave a wrong and non-habitual intoxication, the legal classification of the crime remains Parricide. Because the penalty of reclusion perpetua appeared excessive given the lack of specific malice and the possibility that the victim's death was hastened by a weak constitution or lack of medical care, the Court affirmed the conviction but invoked Article 5 of the RPC to recommend a reduction of the penalty to the Chief Executive.
Main Doctrine
The maltreatment inflicted by a husband on his wife, even without intent to kill, which results in her death, constitutes parricide under Article 4 of the Revised Penal Code, where criminal liability is incurred for any felony although the wrongful act done be different from that which he intended. The penalty of reclusion perpetua may be imposed, but mitigating circumstances such as lack of intent to commit so grave a wrong and intoxication (if not habitual) may be considered in the imposition of the penalty.