G.R. No. L-1612 - Vargas vs. Rilloraza

On November 6, 1993, between 7:30 and 8:30 p.m., the appellant, DOMINGO CASTILLO, JR. (nicknamed aBoyeta), was at the D & G Restaurant in Norzagaray, Bulacan, drinking beer with his father, the victim, Domingo Castillo, Sr.
After about two hours of drinking, a group of noisy customers arrived. Aware of his son’s propensity for fights and the potential trouble these customers could cause, the victim urged his son to leave the restaurant and return home.

The victim and the appellant boarded a blue pick-up truck (plate number CBE 591) heading towards their home in Angat, Bulacan.
During the trip, a drunken argument ensued as the appellant insisted on returning to the restaurant, while the victim opposed the idea, wanting to head straight home.

Nearing their residence, the appellant abruptly stopped the vehicle, and the victim alighted. While still holding a bottle of beer, the victim raised both hands and, standing in front of the truck, provocatively challenged the appellant by saying, “asige kung gusto mo sagasaan mo ako, hindi ka makakaalisa” (go ahead, run over me if you want to leave).
The appellant slowly drove the truck forward, intimidating the victim. When the victim exclaimed, “apapatayin mo ba ako?” (are you going to kill me?), the appellant backed-up nearly hitting a parked jeep and then accelerated, running the truck over the victim.
Not content with a single blow, the appellant put the vehicle in reverse and ran over the victim a second time before alighting and walking toward their house.

Arthur Agaran, an employee at the victim’s recapping shop and present at the victim’s residence at the time, observed the vehicle’s erratic movements (four times moving forward and backward) and noted the subsequent discovery of the victim’s bloodied, sprawled body.
Mariano, a prosecution eyewitness, corroborated the sequence of events including the threatening maneuver of the truck and the subsequent impact on the victim.
Despite the victim’s severe injuries, the appellant did not immediately seek help. Instead, he walked towards the town, leaving the workers to rush the victim to Dolorosa Hospital, where the victim eventually expired.

Initially, the appellant tried to pass off his actions as accidental. However, following inquiries by his older sister, Leslie C. Padilla—who suspected foul play—a formal investigation was conducted by the National Bureau of Investigation (NBI).
The investigation confirmed the suspicions of foul play, leading to the filing of an information for parricide against the appellant.
In trial, Branch 14 of the Regional Trial Court of Bulacan found the appellant guilty beyond reasonable doubt of parricide, sentencing him to reclusion perpetua and ordering him to pay damages.

Testimonies revealed a history of discord between the appellant and his parents, including an incident where his father had a candid “heart to heart” talk concerning the appellant’s lack of employment and dependence on parental support.
This background of resentment was cited as a contributing factor to the heinous nature of the crime, although the precise motivation for the killing remained unclear.

Whether the appellant acted with deliberate intent to kill his father or merely committed an act of reckless imprudence or negligence.
Assessment of whether the use of a pick-up truck to run over his father was premeditated or accidental.

The competency and credibility of the testimonies from prosecution witnesses, specifically Ma. Cecilia Mariano and Arthur Agaran, in detailing the events.
Whether the trial court’s reliance on these testimonies was justified in establishing the malice and deliberate nature of the act.

Whether the circumstances of the incident could be deemed as a case of criminal negligence (reckless imprudence) rather than intentional manslaughter.
The distinction between deliberate intent and inadvertent harm within the context of parricide under the Revised Penal Code.

Evaluation of the award of actual versus moral damages to the other heirs of the victim.