People v. Merced
REITERATIONFacts
The Antecedents: On the night of March 4, 1918, Catalino Merced and Apolonia Patron were invited to supper at the house of Teodora Sarasin. After supper, both defendants retired to a room in Sarasin's house to sleep. Teodora Sarasin, the owner, was awakened by a struggle in the room. She heard Apolonia Patron state she was wounded, and her husband, Pantaleon Arabe, replied, "that is what you got." Fearing the situation, Sarasin left the house and later returned to find Pantaleon Arabe lying on the floor, bloody and with a wound in his stomach. Arabe's body was later found by the justice of the peace on the river bank near the house. Procedural History: The defendants Catalino Merced and Apolonia Patron were charged with homicide. The Court of First Instance of Oriental Negros rendered judgment, sentencing Catalino Merced to fourteen years, eight months, and one day of reclusion temporal and Apolonia Patron to eight years and one day of prision mayor. Both were ordered to pay an indemnity of P1,000 to the heirs of the deceased and costs. The defendants appealed. The Petition: The defendants appealed the judgment of the Court of First Instance.
Issue(s)
Whether the death of Pantaleon Arabe was attended by any qualifying circumstances. Whether Catalino Merced acted in self-defense. Whether Apolonia Patron was an accomplice to the crime of homicide.
Ruling
The judgment of the Court of First Instance was affirmed with respect to Catalino Merced, who was sentenced to fourteen years, eight months, and one day of reclusion temporal, with accessory penalties, and to pay P1,000 to the heirs of the deceased, and one-half of the costs of both instances. The judgment was reversed with respect to Apolonia Patron, who was absolved from the cause. The other one-half of the costs of both instances were to be borne de officio.
Ratio Decidendi
On the qualifying circumstances: The Court held that the death of Pantaleon Arabe was not attended by any qualifying circumstances that would elevate the crime beyond homicide. The record did not show any disinterested eyewitnesses to the struggle, and the owner of the house, Teodora Sarasin, was awakened by the noise and could not see what transpired due to the lack of light. She only identified Pantaleon Arabe as one of the fighters upon finding his bloody body in her room. The mortal wound was inflicted during a struggle, and the circumstances did not indicate treachery or evident premeditation. On self-defense: The Court found the plea of self-defense by Catalino Merced unsustainable. Merced claimed that Arabe entered the house, threatened to kill him, put out the light, and attacked him with a bolo. Merced asserted that he snatched the bolo and wounded Arabe in self-defense. However, the Court found this claim untrue. Even if Arabe did enter and assault Merced, the Court considered such an act as that of an offended husband defending his honor and rights, which, if it resulted in death, might fall under Article 423 of the Penal Code, not the article penalizing homicide. The Court noted that Merced admitted to having illicit relations with Apolonia Patron, the wife of the deceased, and that they were meeting in the house, thus exposing themselves to the vengeance of the offended husband. On Apolonia Patron's participation: The Court held that the record did not disclose conclusive proof that Apolonia Patron cooperated with or aided Catalino Merced in inflicting the mortal wound on her husband. Merced himself confessed to inflicting the wound with a dagger he snatched from Arabe's belt. While Filomena Ago testified to seeing Apolonia Patron with the dagger days before the crime and later seeing blood on Merced's clothes and the dagger on the floor, the Court presumed Merced was the owner of the dagger since he admitted using it. There was no proof that Apolonia Patron carried the dagger that night or furnished it. Therefore, it could not be asserted that she was at least an accomplice. The complaint also did not charge her as an accomplice.
Main Doctrine
The Court affirmed the conviction of Catalino Merced for homicide, finding that the mortal wound was inflicted during a struggle and not attended by qualifying circumstances. The Court reversed the conviction of Apolonia Patron, finding insufficient proof of her participation as an accomplice in the killing of her husband.