People v. Sabalberino
REITERATIONFacts
The Antecedents: William Sabalberino was charged with parricide for allegedly stabbing and killing his wife, Delia Fernandez-Sabalberino, on August 17, 2005. The prosecution presented evidence, including the testimonies of the couple's daughters, Angela and Jessica, who claimed they witnessed their father stab their mother following an argument. The accused, William Sabalberino, admitted to stabbing his wife but asserted it was accidental. He claimed he discovered his wife engaged in sexual intercourse with another man and, in the ensuing struggle for a knife, inadvertently stabbed his wife while attempting to stab the other man. Procedural History: The Regional Trial Court (RTC) of Tacloban City, Branch 6, found William Sabalberino guilty of parricide and sentenced him to reclusion perpetua, along with civil and moral damages. The accused appealed this decision to the Court of Appeals (CA). The CA affirmed the conviction but modified the damages awarded. Sabalberino then filed a Motion for Reconsideration, which the CA denied. Subsequently, he filed a Notice of Appeal to the Supreme Court. The Petition: William Sabalberino, through his appeal to the Supreme Court, seeks to overturn his conviction for parricide. He reiterates his defense that the stabbing was accidental, stemming from discovering his wife in the act of infidelity, and invokes Article 247 of the Revised Penal Code as an absolutory cause. Alternatively, he argues that the trial court erred in not appreciating the mitigating circumstances of passion or obfuscation, voluntary surrender, and lack of intention to commit so grave a wrong. The People of the Philippines, through the Office of the Solicitor General, maintains that the CA correctly upheld the conviction, finding no merit in the accused-appellant's defenses and arguments.
Issue(s)
Whether the Court of Appeals correctly upheld the conviction of the accused-appellant for parricide. Whether the accused-appellant's defense under Article 247 of the Revised Penal Code is tenable. Whether the mitigating circumstances of passion and obfuscation, voluntary surrender, and lack of intention to commit so grave a wrong should be appreciated in favor of the accused-appellant.
Ruling
The Supreme Court dismissed the appeal and affirmed the decision of the Court of Appeals, upholding the conviction of William Sabalberino y Abulencia for parricide. The penalty of reclusion perpetua was affirmed, along with the monetary awards for damages.
Ratio Decidendi
On the conviction for parricide: The Court affirmed the conviction, finding that all elements of parricide were present. The victim, Delia Sabalberino, was killed, the accused-appellant admitted to stabbing her, and the spousal relationship was undisputed, evidenced by a marriage certificate and admitted by the defense. The eyewitness testimonies of the daughters, Angela and Jessica, were found credible and corroborated the prosecution's narrative that the stabbing occurred during a quarrel and not under the circumstances claimed by the accused-appellant. The Court gave significant weight to the trial court's assessment of witness credibility, which was affirmed by the CA, and found no reason to deviate from these findings. On the defense under Article 247 of the Revised Penal Code: The Court found accused-appellant's defense untenable as he failed to prove by clear and convincing evidence that he surprised his wife in the act of committing sexual intercourse with another person. His uncorroborated claim was contradicted by the consistent testimonies of his daughters, who stated no other person was present and that the incident stemmed from a quarrel. The Court reiterated that for Article 247 to apply, the accused must prove the elements thereof, particularly the killing of the spouse and paramour in the act or immediately thereafter, which was not sufficiently established. On the mitigating circumstances: The Court ruled that the mitigating circumstances invoked by the accused-appellant were unavailing. Passion and obfuscation were not appreciated because the quarrel, though heated, did not rise to the level of an uncontrollable burst of passion provoked by prior unjust acts that would overcome reason. Voluntary surrender was not appreciated because there was no showing of spontaneity or intent to unconditionally surrender; the accused-appellant did not ask for the police, and his lack of resistance upon apprehension did not equate to voluntary surrender. The mitigating circumstance of lack of intention to commit so grave a wrong was also rejected, as the use of a deadly weapon and the infliction of a mortal wound on the chest indicated an intent to kill, or at least to inflict a grave injury, which was consistent with the nature of the crime committed.
Main Doctrine
The defense of having surprised one's spouse in the act of infidelity under Article 247 of the Revised Penal Code requires clear and convincing evidence, and uncorroborated claims are insufficient against credible eyewitness testimonies, especially from the victims' children. Mitigating circumstances such as passion and obfuscation, voluntary surrender, and lack of intention to commit so grave a wrong were found unavailing in this case.