People v. Padiernos
REITERATIONFacts
The Antecedents: Nona Salazar Padiernos and Rodolfo Padiernos were married and had four children. On the night of October 22, 1968, the deceased, Rodolfo, came home drunk. The following morning, October 23, 1968, after Nona returned from taking their son to school, she went to the bedroom. Shortly thereafter, she called for help, and the family driver, Roberto Valeriano, found Nona holding a blood-stained knife and the deceased sprawled on the floor, groaning. Nona expressed anger at the deceased for allegedly deceiving her. The deceased was brought to the hospital where he was pronounced dead on arrival. Nona refused to surrender to the police and went into hiding. An investigation of the bedroom revealed bloodstains and the deceased's gun under the mattress. The knife used was also recovered. An autopsy revealed the deceased sustained one lacerated wound and three stab wounds, which caused his death. Procedural History: The Court of First Instance of Rizal found Nona Salazar Padiernos guilty of parricide, sentencing her to life imprisonment, accessory penalties, and to indemnify the heirs of the deceased. The accused appealed this decision. The Petition: The accused appealed, maintaining that the trial court erred in rejecting her claim of self-defense and in giving weight to the prosecution witnesses' testimonies.
Issue(s)
Whether the appellant's claim of self-defense is tenable. Whether the trial court erred in admitting and giving weight to the testimonies of the prosecution witnesses.
Ruling
The judgment of the court a quo finding the accused Nona Salazar Padiernos guilty of parricide is affirmed in toto. The accused is sentenced to life imprisonment with the corresponding accessory penalties, and to indemnify the heirs of the deceased in the amount of P20,000.00, with costs.
Ratio Decidendi
On the issue of self-defense: The appellant's plea of self-defense is untenable. If the wounds were inflicted as claimed by the appellant, by swinging the knife sidewise, the deceased would have sustained slash wounds, not stab wounds. The autopsy report, however, shows three stab wounds, one of which, the fatal wound, was located at the left part of the deceased's back. These physical facts belie and negate the appellant's claim of self-defense, as they indicate the wounds were inflicted while the appellant was behind the deceased. Furthermore, the appellant's version of the incident is highly incredible and improbable; specifically, it is questioned how she could have hit her husband without seeing him while covering her eyes, and why the deceased, if armed and angry, did not shoot her but remained immobile. The appellant's conduct after the stabbing incident, which involved fleeing and going into hiding for almost four years, is inconsistent with a claim of self-defense and tends to establish her guilt. It is a well-settled rule that one who admits inflicting injuries causing death has the burden of proving self-defense with sufficient and convincing evidence. Having failed to prove her plea by clear and convincing evidence, the appellant must suffer the consequences of her unlawful act. On the credibility of prosecution witnesses: The rule consistently adhered to by the Supreme Court is to give due respect to the trial court's findings on the credibility of witnesses, as the trial court had the opportunity to observe their demeanor. Appellate tribunals will not disturb these findings unless there is proof that the court failed to appreciate a fact or circumstance of weight and substance. The contention that prosecution witness Letty Basa is biased due to her relationship with the deceased is without merit, as her declarations were reasonable, consistent, and supported by facts. The argument that the non-presentation of Letty Basa's alleged unsigned statement to the police gave rise to a presumption of unfavorable content is also without merit, as the presumption of suppressed evidence does not apply when the evidence was available to both parties. The defense could have subpoenaed the statement but failed to do so. The contention that Dr. Ernesto Brion was not competent to testify because Dr. Enrique Jimenez conducted the autopsy is also devoid of merit. Dr. Brion testified that the autopsy was conducted under his direct supervision, and his competency as an expert witness was admitted by the appellant's counsel. His testimony, corroborated by other prosecution witnesses, was found to be credible by the trial court.
Main Doctrine
The claim of self-defense is untenable when the nature and location of stab wounds, particularly a fatal wound at the back, belie the accused's version of the incident and indicate that the wounds were inflicted from behind. Furthermore, the accused's flight and failure to surrender immediately after the incident are inconsistent with a claim of self-defense and tend to establish guilt. The burden of proving self-defense rests on the accused, and if the evidence presented is doubtful or not clear and convincing, the defense must fail.