Case Digest (G.R. No. 140794)
Facts:
The case is an appeal from the September 14, 1997 Decision of the Regional Trial Court of San Carlos City (Branch 57) in Criminal Case No. SCC 3054 in which the court found Ricardo Agliday y Tolentino guilty beyond reasonable doubt of parricide for the February 25, 1999 shooting in Barangay Nalsian Sur, Bayambang, Pangasinan, and sentenced him to suffer reclusion perpetua and to indemnify the heirs in the amount of fifty thousand pesos (50,000.00), with the shotgun ordered turned over to the Firearm and Explosive Division. The prosecution presented eyewitness testimony of appellant’s wife Conchita Agliday and son Rey Agliday that appellant retrieved a shotgun during a quarrel and shot his son Richard V. Agliday, who died; appellant pleaded accidental discharge while cleaning a homemade shotgun and surrendered to the barangay captain, and he appealed the conviction to the Supreme Court.
Issues:
- Did the trial court err in its findings of fact warranting an acquittal for the accused?
- Did the trial court err in convicting the accused of parricide instead of a lesser offense such as reckless imprudence resulting in homicide?
Ruling:
The Supreme Court denied the appeal and affirmed the trial court’s conviction and sentence for parricide, including the award of indemnity and the turnover order for the firearm. The Court upheld the trial court’s credibility determinations and rejected appellant’s claim of accidental discharge, with costs imposed on appellant.
Ratio:
The Court deferred to the trial court’s acceptance of the eyewitness testimonies as straightforward and credible, finding no basis to disturb those factual findings. Under Article 12 (paragraph 4) of the Revised Penal Code, accident exempts criminal liability only where the actor performs a lawful act with due care and causes injury by mere accident without fault or intent; firing a shotgun is not a lawful act and the act of cocking and discharging the weapon showed intent, thus negating the accident defense and demonstrating malice rather than reckless imprudence.
Doctrine:
- Appellate courts will not disturb trial court findings on witness credibility unless those findings are clearly unsupported by the evidence.
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