Case Digest (G.R. No. 219510)
Facts:
In People of the Philippines vs. Paulino Delos Santos, Jr. alias “Skylab” (G.R. No. 248929, November 9, 2020), the accused-appellant, Paulino Delos Santos, Jr., was charged with parricide under Article 246 of the Revised Penal Code for stabbing his father, Paulino Delos Santos, Sr., on the night of May 8, 2011 at Purok 2, Barangay Macolabo Island, Paracale, Camarines Norte. The case was docketed as Criminal Case No. 14834 before the Regional Trial Court (RTC), Branch 39, Daet, Camarines Norte, where appellant pleaded “not guilty.” During trial, the prosecution presented three witnesses: Michael L. San Gabriel, who positively identified appellant as the killer; Police Officer 3 Gil V. Obog, who investigated the scene; and Dr. Virginia B. Mazo, who issued the victim’s death certificate attributing death to a stab wound. Appellant testified in his own defense, claiming an alibi and denying involvement. On September 5, 2016, the RTC convicted appellant of parricide and sentenced himCase Digest (G.R. No. 219510)
Facts:
- The Case
- This appeal stems from the Decision of the Court of Appeals (CA-G.R. CR-HC No. 08894, June 28, 2018) which affirmed with modification the September 5, 2016 conviction of Paulino Delos Santos, Jr. alias “Skylab” for parricide.
- The CA ordered six percent legal interest per annum on monetary awards from finality of its decision until full payment.
- Proceedings Before the Trial Court
- Information and Arraignment
- Appellant was charged with parricide for stabbing his father, Paulino Delos Santos, Sr., on May 8, 2011 at Purok 2, Brgy. Macolabo Island, Paracale, Camarines Norte.
- Appellant pleaded “not guilty” when arraigned before RTC–Daet, Camarines Norte (Branch 39), Criminal Case No. 14834.
- Trial
- Prosecution witnesses: Michael L. San Gabriel, Dr. Virginia B. Mazo, and PO3 Gil V. Obog.
- Defense witness: Appellant himself.
- Factual Background
- Prosecution’s Version
- Around 11:30 PM on May 8, 2011, appellant, intoxicated and armed with a knife, arrived at a gathering in Purok 3. He argued first with his brother Marcos, then with his father, who urged him to leave.
- In the ensuing scuffle, appellant stabbed his father in the left chest, causing instantaneous death. Witness Michael positively identified appellant as the killer.
- PO3 Obog attended the crime scene; Dr. Mazo issued the death certificate attributing death to a stab wound.
- Defense’s Version
- Appellant claimed he awakened to a commotion at his brother-in-law’s house, saw blood on Jovito, and was barred from entering; he denied stabbing his father.
- Trial Court Ruling
- By Decision dated September 5, 2016, RTC found all elements of parricide proven beyond reasonable doubt.
- Appellant was sentenced to reclusion perpetua (without eligibility for parole), ordered to pay ₱75,000 civil indemnity, ₱50,000 moral damages, and ₱30,000 exemplary damages.
- Proceedings Before the Court of Appeals
- Appellant argued failure to prove motive, lack of corroboration, and insufficient details in Michael’s testimony.
- OSG maintained the lone eyewitness testimony and identification sufficed despite absence of motive or additional witnesses.
- CA denied the appeal, modified only to impose six percent interest on damages.
- Present Appeal to the Supreme Court
- Appellant renewed his claim for acquittal, adopting his CA briefs.
- Issue before the Court: Whether the CA erred in affirming the conviction for parricide.
Issues:
- Whether the Court of Appeals erred in affirming appellant’s conviction for parricide despite alleged deficiencies in motive, detail, and witness corroboration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)