People v.

Talingdan
G.R. No. L-32126 July 6, 1978
FACTS
1. Bernardo Bagabag and appellant Teresa Domogma’s relationship had been strained and
beset with troubles, for Teresa had deserted their family home a couple of times and
have been having illicit relations with co-appellant Talingdan.
2. Bernardo and Teresa had a violent quarrel, the latter sought the help of the police and
shortly thereafter, accused Talingdan, a police officer, came to the vicinity and called
Bernardo to come down; but Bernardo ignored him, so the latter left the place, warning
Bernardo that someday he would kill him.
3. The following day, Corazon, the daughter of Bagabag and Domogma, saw her mother
meeting with Talingdan and their co-appellants in a small hut.
4. Shortly after the sun had set on the following day, Corazon she saw her mother go down
the house through the stairs and go to the yard where she again met with the other
appellants. She noted that the appellants had long guns at the time. After their meeting,
Teresa came up the house and proceeded to her room, while the other appellants went
under an avocado tree nearby.
5. Bernardo was at the kitchen and sat himself on the floor near the door. At that moment,
he was suddenly fired upon from below the stairs, the accused then climbed the stairs
carrying their long guns and seeing that Bernardo was still alive, fired at him again.
6. Teresa came out of her room; she pulled Corazon aside and questioned her, and when
Corazon informed her that she recognized the killers of her father to be her co-
appellants herein, she warned her not to reveal the matter to anyone, threatening to kill
her if she ever did so.
7. During trial, because no certificate nor any other proof of their marriage could be
presented by the prosecution, Teresa, could not be charged with parricide.
ISSUE
WON Teresa shall incur criminal liability?

RULING
The SC ruled that Teresa shall be at the very least an accessory to the offense committed
by her co-accused. She was inside the room when her husband was shot. As she came out after
the shooting, she inquired from Corazon if she was able to recognize the assailants of her
father. When Corazon Identified the appellants as the culprits, Teresa did not only enjoin her
daughter not to reveal what she knew to anyone, she went to the extent of threatening her
daughter with death if she was to tell anyone. Later, when the peace officers were investigating
what happened, instead of helping them with the information given to her by Corazon, she
claimed she had no suspects in mind. These subsequent acts of her constitute "concealing or
assisting in the escape of the principal in the crime" which makes her liable as an accessory
after the fact under paragraph 3 of Article 19 of the Revised Penal Code.