### Facts:
The case revolves around Victoriano dela Cruz y Lorenzo, who was charged with the crime of parricide for the death of his wife, Anna Liza Caparas-dela Cruz, on August 18, 2002, in Malolos, Bulacan, Philippines. Upon arraignment, Victoriano pleaded not guilty and the trial ensued, presenting two conflicting versions of the events leading to Anna’s death.
#### Version of the Prosecution:
Joel Song, a witness, observed Victoriano assaulting Anna near their home and then dragging her inside. Subsequently, the couple emerged with Victoriano supporting a bleeding Anna, who was then taken to Bulacan Provincial Hospital but succumbed to her injuries. The Medical Legal Report indicated severe physical injuries and a fatal stab wound.
#### Version of the Defense:
Victoriano claimed the incident occurred when he, intoxicated, returned home and accidentally pushed Anna resulting in her falling onto a shattered window. He denied intentionally harming Anna, asserting that the wound was accidental.
#### Procedural Posture:
After the RTC of Malolos, Bulacan found Victoriano guilty of parricide, sentencing him to reclusion perpetua and ordering compensation to the victim’s heirs, the decision was appealed. The Court of Appeals affirmed with minor modifications the RTC’s decision. Victoriano filed a subsequent appeal to the Supreme Court of the Philippines, asserting errors in the appreciation of evidence and proposing mitigating circumstances, including intoxication.
### Issues:
1. Whether circumstantial evidence was sufficient for conviction.
2. Whether Victoriano’s act constituted an “accident” exempting him from criminal liability.
3. Whether intoxication could be considered a mitigating factor in this case.
### Court’s Decision:
The Supreme Court affirmed the conviction of Victoriano dela Cruz for parricide, emphasizing the sufficiency of circumstantial evidence that led to an unquestionable conclusion of his guilt. It rejected the defense’s argument of the incident being an accident, highlighting that the sequence of Victoriano’s violent actions was far from a lawful act. Furthermore, the Court found no substantial proof that Victoriano’s intoxication significantly impaired his mental faculties to merit consideration as a mitigating factor.
### Doctrine:
The Supreme Court reiterated that circumstantial evidence could lead to a conviction provided it fulfills specific criteria ensuring its reliability. It also reinforced the principle that for an accident to be considered an exempting circumstance, the act leading to injury must be lawful, which was not the case in Victoriano’s violent conduct towards his wife.
### Class Notes:
1. **Circumstantial Evidence**: Conviction can rely on circumstantial evidence if it forms an unbroken chain leading to the only rational conclusion of guilt.
2. **Parricide under Article 246 of the RPC**: Requires the killing of a spouse, among others, by the accused.
3. **Exempting Circumstance – Accident (Article 12, paragraph 4, RPC)**: Must be a lawful act performed with due care resulting in unintended harm.
4. **Mitigating Circumstance – Intoxication**: To be considered, intoxication must not be habitual or subsequent to a plan to commit a felony, and it must impair the offender’s mental faculties.
### Historical Background:
The case underscores the legal and societal condemnation of violence against family members, particularly against spouses. It exemplifies the complexities involved in cases of domestic violence where claims of accidents and self-defense often intersect with the issues of intent and culpability. The decision reinforces the stringent scrutiny applied by the judiciary in such sensitive cases, ensuring that justice is served while safeguarding the rights of all parties involved.
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