PEOPLE OF THE PHILIPPINES VS RENATO ESPAÑOL
G.R. No. 175603, February 13, 2009
Parricide
G.R. No. 175603, February 13, 2009
Parricide
FACTS:
At
about 2:00 a.m. of February 2, 2000, Domingo Petilla was waiting for
his companions at Pantal Road, Dagupan City on their way to Manila. All
of a sudden, he heard two successive gunshots. A few moments later, a
yellow tricycle sped past him along Pantal Road headed towards Sitio
Guibang, Dagupan City. The tricycle was driven by a man wearing a
dark-colored long-sleeved shirt. Petilla’s companions arrived shortly
thereafter on board a van. As they started loading their things, they
saw, through the lights of their vehicle, a person lying on the pavement
along Pantal Road. Upon closer scrutiny, they discovered the lifeless
body of Gloria Español. The gunshots were also heard by Harold
Villanueva,
a boatman working at the Pantal River, while he was waiting for
passengers at the dock about 100 meters away from the crime scene. The
shots were followed by the sound of a motorcycle’s revving engine. He
then saw a speeding yellow tricycle. The tricycle bore the name “Rina”
in front of its cab. Its driver was wearing a dark jacket and blue
pants. Out of curiosity, he (the boatman) went
there and recognized the victim as one of his regular passengers.
Appellant arrived at the scene and Villanueva noticed that the appellant
seemed to be wearing the same clothes as those worn by the driver of
the speeding tricycle. He was subsequently charged of parricide.
ISSUE:
Is the accused guilty of parricide?
RULING:
YES.
Under Article 246 of the Revised Penal Code, parricide is the killing
of one’s legitimate or illegitimate father, mother, child, any
ascendant, descendant or spouse and is punishable by the single
indivisible penalty of reclusion perpetua to death. None of the
prosecution witnesses saw the actual killing of the victim by
appellant. However, their separate and detailed accounts of the
surrounding circumstances reveal only one conclusion: that it was
appellant who killed his wife.
Well-entrenched is the rule that the trial court’s evaluation of the
testimonies of witnesses is accorded great respect in the absence of
proof that it was arrived at arbitrarily or that the trial court
overlooked material facts. The rationale behind this rule is that the
credibility of a witness can best be determined by the trial court since
it has the direct opportunity to observe the candor and demeanor of the
witnesses at the witness stand and detect if they are telling the truth
or not. The Court will not interfere with the trial court's assessment of the credibility of witnesses.In sum, the guilt of appellant was sufficiently established by circumstantial evidence. Reclusion perpetua was correctly imposed considering that there was neither any mitigating nor aggravating circumstance present. The heirs of the victim are entitled to a civil indemnity ex delicto of P50,000, which is mandatory upon proof of the fact of death of the victim and the culpability of the accused for the death.