People vs. Arcilla

G.R. No. 116237 (May 15, 1996)

Facts:

The case involves Fe Arcilla y Cornejo, who was charged with parricide for the stabbing death of her husband, Antonio F. Arcilla. The incident occurred on May 1, 1992, in Barangay Namantao, Daraga, Albay. Fe and Antonio were married on April 19, 1975, and had five children. Fe worked as a teacher and had left the family in 1983 to work in Singapore, while Antonio remained in the Philippines, where he developed an extramarital affair with Lilia Lipio, with whom he had two children.

Upon returning to the Philippines in 1988, Fe discovered Antonio's infidelity, which continued despite her presence. On the day of the incident, Fe went to Lilia's residence looking for Antonio, who was found drinking with friends. A confrontation ensued between Fe and Antonio, escalating into violence. During the altercation, Fe retrieved a fan knife from her bag and stabbed Antonio twice, once in the chest and once in the thigh. Antonio was rushed to the hospital but succumbed to his injuries.

Fe's defense claimed that the stabbing was accidental, resulting from a struggle over the knife. She testified that she was pushed by Antonio, which led to the knife inadvertently striking him. The trial court, however, found the prosecution's evidence, particularly the testimony of Lilia Lipio, credible and sufficient to convict Fe of parricide.

Legal Issues:

1. Whether the trial court erred in admitting the testimony of Lilia Lipio in the absence of a public prosecutor.
2. Whether the trial court erred in giving credence to Lilia Lipio's testimony regarding the circumstances leading to Antonio's death.
3. Whether the trial court erred in not giving credence to Fe's testimony regarding the circumstances of the stabbing.

Arguments:

• Prosecution's Argument: The prosecution presented Lilia Lipio as a key witness, asserting that she witnessed the stabbing and the events leading up to it. Lilia testified that Fe approached Antonio with a knife and stabbed him during a heated argument. The prosecution argued that Fe's actions were intentional and constituted parricide.

• Defense's Argument: The defense contended that the stabbing was accidental, resulting from a struggle between Fe and Antonio over the knife. Fe claimed that she was provoked by Antonio's actions and that she did not intend to kill him. The defense also challenged the credibility of Lilia's testimony, arguing that her relationship with Antonio biased her account.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, rejecting the appellant's arguments. It ruled that the absence of the public prosecutor during Lilia's testimony did not invalidate her statements, as the defense had the opportunity to cross-examine her and did not demonstrate any prejudice. The court emphasized that the presence of a public prosecutor is essential for protecting state interests, but a momentary absence does not undermine the integrity of the testimony.

Regarding the credibility of Lilia's testimony, the court found her account clear and consistent, corroborated by the circumstances of the incident. The trial court's assessment of witness credibility was given great weight, as it had the opportunity to observe the demeanor of the witnesses firsthand.

The court also dismissed Fe's claim of accidental stabbing, noting that the nature of the wounds and the circumstances surrounding the altercation indicated intent. The court concluded that Fe's actions were not justifiable, as she had provoked the confrontation and had the opportunity to seek help from bystanders.

In terms of sentencing, the court clarified that reclusion perpetua is an indivisible penalty, thus rejecting the defense's request for consideration of mitigating circumstances. The court ultimately sentenced Fe to reclusion perpetua without any divisible period.

Significant Legal Principles Established:

1. The momentary absence of a public prosecutor during witness testimony does not invalidate the testimony if the defense has the opportunity to cross-examine the witness and does not demonstrate prejudice.
2. The trial court's assessment of witness credibility is given great deference, particularly when it has the opportunity to observe the witnesses' demeanor.
3. The nature of the wounds and the circumstances of the altercation can negate claims of accidental injury, particularly in cases involving domestic violence.