Case Digest (G.R. No. 139339)
Facts:
People of the Philippines v. Manuel Castillo y Gomez, G.R. No. 139339, January 19, 2001, the Supreme Court First Division, Davide Jr., C.J., writing for the Court.The accused-appellant is Manuel Castillo y Gomez (MANUEL); the victim was his mother, Rosenda (Gomez) Castillo. MANUEL was charged in an information dated November 19, 1994 with the crime of parricide (Article 246, Revised Penal Code) for allegedly mauling Rosenda on the night of 16–17 November 1994, inflicting multiple injuries that resulted in intracranial hemorrhage and death. MANUEL pleaded not guilty and waived pretrial.
At the Regional Trial Court (RTC), Branch 9, Davao City (Criminal Case No. 34,701-94), the prosecution offered testimony from Dr. Danilo P. Ledesma (medico-legal officer who performed the autopsy), and eyewitness Maria Theresa Castillo (Theresa) and Anacorita Castillo (Anacorita). Dr. Ledesma’s necropsy report showed extensive external and internal injuries—including multiple contusions and rib fractures, lacerated lungs, hemothorax, and severe intracranial hemorrhage—finding traumatic intracranial hemorrhage as the cause of death. Theresa testified she saw MANUEL, while intoxicated, kick and beat Rosenda repeatedly beginning about 10:00 p.m., leaving Rosenda seriously injured and dying; Theresa intervened and MANUEL eventually stopped.
The defense presented family members (Rodel, Josie, Lisa), MANUEL himself, plus Atty. Isaac Robillo and State Prosecutor Manuel Batao. Rodel and Josie denied seeing any injuries or disturbance that night and depicted the death as natural; MANUEL described finding Rosenda dead the next morning and denied knowledge he had killed her. Three affidavits of desistance were introduced by the defense: Theresa’s, Anacorita’s, and a joint affidavit by Anacorita and Salvador (another sibling); the affiants later either testified for the prosecution or were unavailable (Anacorita died; Salvador was reportedly ill). Defense counsel did not confront the witnesses Theresa and Anacorita with their earlier affidavits at trial.
On April 19, 1999 the RTC convicted MANUEL of parricide and sentenced him to reclusion perpetua with attendant penalties, but (erroneously, in the Supreme Court’s view) absolved him of civil liability based on the affidavits of desistance. MANUEL appealed his conviction to this Court challenging (1) the sufficiency of t...(Subscriber-Only)
Issues:
- Whether the prosecution proved beyond reasonable doubt that Manuel Castillo y Gomez committed parricide.
- Whether the trial court erred in refusing to accord probative value to the affidavits of desistance (and whether failure to confront the affiants affected their evidentiary weight).
- Whether the trial court correctly absolved the accused of civil liability on the basi...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)