PEOPLE v. MANUEL MACAL Y BOLASCO

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PEOPLE v. MANUEL MACAL Y BOLASCO, GR No.

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:

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