In the Philippines, the sanctity of marriage does not justify violence. This case underscores that infidelity, whether real or perceived, offers no legal defense for spousal violence. The Supreme Court affirmed the conviction of Abenir Brusola for parricide, emphasizing that a husband’s jealousy and rage do not excuse the brutal killing of his wife. The decision reinforces the principle that all individuals are entitled to protection under the law, irrespective of marital disputes, and that violence is never an acceptable resolution. This ruling serves as a stark reminder of the legal consequences of domestic violence and the state’s commitment to upholding the right to life.

Driven by Jealousy: When a Husband’s Accusations Turn Deadly

The case of People of the Philippines vs. Abenir Brusola revolves around the tragic death of Delia Brusola, who was killed by her husband, Abenir, with a mallet. Abenir claimed he acted in a fit of rage upon witnessing Delia with another man, arguing that his actions were driven by passion and obfuscation. However, the prosecution presented a compelling case, supported by eyewitness testimony from their children, that Abenir intentionally struck Delia on the head with the mallet, resulting in her death. The central legal question is whether Abenir’s actions constitute parricide, defined under Article 246 of the Revised Penal Code, and whether his claims of mitigating circumstances warrant a lesser penalty.

Article 246 of the Revised Penal Code explicitly defines parricide as the killing of one’s father, mother, child, ascendant, descendant, or spouse. It prescribes the penalty of reclusion perpetua to death. The law states:

Article 246. Parricide. – Any person who shall kill his father, mother, or child, whether legitimate or illegitimate, or any of his ascendants, or descendants, or his spouse, shall be guilty of parricide and shall be punished by the penalty of reclusion perpetua to death.

In this case, the key elements of parricide—the marital relationship between Abenir and Delia and the act of killing—were undisputed. The trial court and the Court of Appeals both found the testimony of Joanne, Abenir and Delia’s daughter, to be credible and decisive. Joanne testified that she witnessed her father striking her mother on the head with a mallet. This direct eyewitness account was critical in establishing Abenir’s guilt beyond a reasonable doubt. The courts gave weight to Joanne’s testimony because it is unusual for a family member to falsely accuse another of such a heinous crime.

Abenir challenged the consistency of the testimonies provided by Joanne and Abegail, arguing that their statements contained contradictions. However, the Court of Appeals dismissed these inconsistencies as minor details that did not undermine the overall credibility of the witnesses. The court reasoned that discrepancies on insignificant details are common and often indicate that the witnesses were not coached or their testimonies rehearsed. What mattered most was the consistency in their accounts of the principal event—Abenir striking Delia with the mallet.

The defense also argued that Joanne harbored ill motives against Abenir due to his disapproval of her plans for an early marriage. The Court of Appeals deemed this claim unworthy of belief, emphasizing that Joanne and her siblings had already suffered the loss of their mother and were now facing the potential loss of their father to imprisonment. It was highly improbable that Joanne would falsely accuse her own father of such a serious crime based on a prior disagreement. Her testimony was viewed as sincere and credible, further solidifying the prosecution’s case.

Abenir further contended that the trial court failed to consider mitigating circumstances, such as passion, obfuscation, and voluntary surrender, in imposing the penalty of reclusion perpetua. However, the courts found no basis for these mitigating circumstances. Passion and obfuscation typically arise from lawful sentiments, which were not evident in this case. Abenir’s claim of acting in a fit of jealous rage did not justify his violent actions. While he did surrender to the authorities, the presence of only one mitigating circumstance did not warrant a lesser penalty than reclusion perpetua, given the severity of the crime of parricide.

In determining the appropriate penalty, the Supreme Court referenced the case of People v. Sales, which elucidates the application of indivisible penalties. According to Article 63 of the Revised Penal Code, when a crime is punishable by two indivisible penalties (such as reclusion perpetua to death), and only one mitigating circumstance is present, the lesser penalty (reclusion perpetua) shall be applied. The court clarified that Article 64, which deals with penalties containing three periods, is not applicable in parricide cases.

The Supreme Court addressed the issue of damages. It increased the civil indemnity and moral damages awarded to the victim’s children to P75,000.00 each. Additionally, the court awarded P75,000.00 as exemplary damages, aligning with prevailing jurisprudence. This adjustment reflects the gravity of the crime and the emotional and financial toll on the victim’s family. The court also imposed a six percent (6%) per annum interest on the awarded damages from the date of finality of the judgment until fully paid.

FAQs

What is parricide under Philippine law?	Parricide is the act of killing one’s father, mother, child, ascendant, descendant, or spouse. It is defined and penalized under Article 246 of the Revised Penal Code, carrying a penalty of reclusion perpetua to death.
What was the key evidence in convicting Abenir Brusola?	The direct eyewitness testimony of Joanne, Abenir’s daughter, was crucial. She testified that she saw Abenir hit her mother, Delia, on the head with a mallet, which directly led to her death.
Did the court consider Abenir’s claim of acting in a fit of jealous rage?	The court rejected this claim as a justification for the crime. While Abenir argued he was provoked by seeing his wife with another man, this did not excuse his violent actions or mitigate the severity of the offense.
What mitigating circumstances did Abenir claim?	Abenir claimed passion, obfuscation, and voluntary surrender as mitigating circumstances. However, the court only acknowledged voluntary surrender, and even then, it was not enough to reduce the penalty below reclusion perpetua.
How did the court determine the appropriate penalty?	The court applied Article 63 of the Revised Penal Code, which governs cases with two indivisible penalties. Since there was only one mitigating circumstance (voluntary surrender), the lesser penalty of reclusion perpetua was imposed.
What damages were awarded to the victim’s family?	The court awarded P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages to the victim’s children. These amounts were increased from the trial court’s initial award to align with current jurisprudence.
Can inconsistencies in witness testimonies affect the outcome of a case?	Minor inconsistencies that do not pertain to the main elements of the crime typically do not affect the credibility of the witnesses. In this case, the court found that the inconsistencies were insignificant and did not undermine the overall credibility of the testimonies.
What is the significance of this case in Philippine jurisprudence?	This case reinforces the principle that violence is never justified in marital disputes and that all individuals are entitled to protection under the law. It also clarifies the application of penalties in parricide cases, ensuring consistency with the Revised Penal Code.

In conclusion, the Supreme Court’s decision in People of the Philippines vs. Abenir Brusola serves as a firm reminder that domestic violence is a serious crime with severe legal consequences. The ruling underscores the importance of upholding the sanctity of life and ensuring that perpetrators are held accountable for their actions, regardless of marital disputes or claims of mitigating circumstances.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Brusola, G.R. No. 210615, July 26, 2017