G.R. No. 215742 - People vs. Umapas y Crisostomo

On November 30, 1998 at around 11:00 PM, appellant Jose Belmar Umapas y Crisostomo allegedly mauled his wife, Gemma Gulang Umapas, at their home in Lower Kalakhan, Olongapo City, then doused her with Coleman alcohol and set her ablaze.
Rodrigo Dacanay brought Gemma to James L. Gordon Memorial Hospital, informing Dr. Arnildo C. Tamayo that appellant was responsible. Gemma suffered contusions on the left cheek and lower lip, lacerations on the right parietal and left temporal areas, and second-degree burns over 57% of her body. She died on December 5, 1998 from multiple organ failure secondary to thermal burns.

On December 1, 1998 at about 1:30 PM, SPO1 Anthony Garcia interviewed Gemma, who, though in pain, coherently identified her husband as her attacker and stated that she felt she was dying.
Garcia reduced her statement into writing; it was thumb-marked by Gemma and witnessed by a hospital nurse.

On January 5, 1999, an Information for parricide was filed, alleging intent to kill, use of superior strength, and premeditation in pouring alcohol on Gemma and setting her body aflame.
On June 7, 1999, appellant pleaded not guilty, asserting alibi: he was fishing with a friend named Rommel and only learned of the incident upon his return.

Dr. Tamayo—testified to Gemma’s injuries, low chance of survival, and being told by Dacanay that appellant doused and set her on fire; authenticated the medical certificate.
SPO1 Garcia—recounted obtaining Gemma’s statement identifying appellant as her assailant.
PO1 Rommel Belisario—testified he was prevented from talking to Gemma initially; at the crime scene, victim’s daughter said appellant set her mother on fire (statement not reduced in writing).

Defense witness: appellant—denied involvement, insisted on alibi, and attributed the accusation to Gemma’s suspicion of his alleged womanizing. No corroborating witness was presented.

October 10, 2011 (RTC, Olongapo City, Crim. Case No. 611-98): Convicted appellant of parricide, sentenced him to reclusion perpetua, and ordered payment of civil (₱50,000), moral (₱50,000), and temperate (₱25,000) damages.
February 26, 2014 (CA, CA-G.R. CR-HC No. 05424): Denied appellant’s appeal, affirmed the RTC Decision with modification adding exemplary damages of ₱30,000; all damages to earn 6% interest from finality.

Whether the Court of Appeals gravely erred in convicting appellant based on the victim’s dying statement, admitting it as a dying declaration and part of res gestae.
Whether the Court of Appeals erred in upholding the conviction despite alleged failure of the prosecution to prove guilt beyond reasonable doubt.