Case Digest (G.R. No. 141767)
Facts:
People of the Philippines v. Hilarion Teves y Cantor, G.R. No. 141767, April 02, 2001, the Supreme Court En Banc, De Leon, Jr., J., writing for the Court.The prosecution charged Hilarion C. Teves (accused-appellant) with parricide under Article 246, Revised Penal Code, as amended and restored by R.A. No. 7659, for the killing of his wife, Teresita Teves y Capuchino, allegedly occurring on August 25, 1996 in Santa Rosa, Laguna. The victim’s body was discovered late evening of August 25, 1996 on an isolated NIA road; the autopsy concluded cause of death was asphyxia by strangulation and noted a nonpenetrating punctured wound in the left pectoral region and other contusions. A group of four barangay tanods patrolling the area found the body and later reported meeting a passenger jeep shortly before discovering the cadaver.
Police investigation identified the driver of the passenger jeep as the appellant. On December 3, 1996 an Information for parricide was filed; appellant pleaded not guilty at arraignment on January 13, 1997. At trial the prosecution relied on circumstantial evidence: testimony of barangay tanod Milagros Tayawa (who later identified appellant and his jeep), other witnesses recounting marital discord between appellant and the victim, and the autopsy report. The prosecution admitted several exhibits including the autopsy report, a cigarette-foil note of a partial plate number and sworn statements.
The trial court (Regional Trial Court, Biñan, Laguna, Branch 25) convicted appellant of parricide and, finding aggravating circumstances—killing at nighttime, in an uninhabited place, and with the use of a motor vehicle—sentenced him to death and awarded moral damages (Decision rendered December 7, 1999). Appellant appealed to the Supreme Co...(Subscriber-Only)
Issues:
- Did the prosecution prove the guilt of the accused beyond reasonable doubt by circumstantial evidence?
- Was the pretrial identification of the appellant by the barangay tanod reliable and admissible given the circumstances of the confrontation?
- Did the trial court properly credit the testimonies of Milagros Tayawa and Maria Alulod?
- Did the trial court appropriately interpret the medico-legal testimony of Dr. Erwin Escal?
- Was the trial court justified in disregarding the appellant’s defense of alibi?
- Were the aggravating circumstances properly ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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