People of the Philippines vs. Honorio Tibon, G.R No. 188320 – Case Digest

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Honorio Tibon and his common law wife, Gina Tibon, have been living together as husband and wife since 1994. Due to financial problems, Gina went to Hongkong to work, leaving his two sons, Reguel and Keen, to her husband Honorio’s custody. After some time, Honorio heard from his sister, who’s also working in Hongkong that Gina had been cheating on him. Honorio became a drunkard after that and was often seen beating his children. One night, Honorio’s mother and siblings went to check him and his children in his room. They saw the children lying lifeless on the floor with several stabs on their chest. Upon seeing his mother and siblings, Honorio stabbed himself with a kitchen knife and tried to end his life by jumping out the window.


Whether or not the accused is guilty of parricide.


Yes. Under Art. 246 of the Revised Penal Code, Parricide 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 ascendant or other descendant, or the legitimate spouse of the accused. The prosecution sufficiently established evidence that Tibon voluntarily killed his two children on the night of December 12, 1998. Moreover, the appeal admits that parricide has indeed been committed. However, the defense of Honorio Tibon’s insanity during the crime does not exempt him from the punishment. There was no sufficient evidence that Honorio was insane when he stabbed his two young sons. The change in his behavior was triggered by jealousy and anger and is not equivalent to insanity.