G.R. No. 79156 - Animos vs. Philippine Veterans Affairs Office

The case involves the People of the Philippines prosecuting Francisco Villar and Angel San Andres for the crime of murder.
The information stated that on or about August 24, 1977, in Caloocan City, Metro-Manila, the accused, conspiring together without justification, attacked, assaulted, and fatally stabbed Arturo C. Pineda with a bladed instrument, inflicting injuries that led to his death.

Angel San Andres was acquitted on June 27, 1979.
Francisco Villar, originally pleading not guilty, changed his plea to guilty on January 16, 1979, after the prosecution had presented its evidence.
Villar’s guilt was never contested in his brief, with his own admission confirming he was the perpetrator.

On March 30, 1979, the trial court sentenced Francisco Villar to Reclusion Perpetua, mandated him to indemnify the heirs of the deceased in the sum of Twelve Thousand Pesos (₱12,000.00), and imposed the payment of costs.
The conviction was based on the clear evidence of his guilt, with no aggravating or mitigating circumstances initially recognized.

Villar invoked his minority as a privileged mitigating circumstance after pleading guilty.
The defense presented evidence to establish his alleged minority:

Exhibit 1 – A certified copy of a Certificate of Live Birth indicating he was born on October 26, 1961. This certificate, however, was prepared and submitted by his mother, Leonor Villar, on January 12, 1979, nearly 17 years after his birth and just 4 days before he changed his plea.
Testimonies from Leonor Villar, affirming his birth details, including his baptism on December 25, 1961, though the baptismal certificate was not produced.
Francisco Villar’s own statement claiming that he was born on October 26, 1961 and that his age at the time of the crime was “only 15 years going to 16 years.”
Testimonies from his siblings, Evelyn and Manuel Villar, reinforcing the birth date provided in Exhibit 1.

Conversely, the prosecution relied on Exhibit E – Villar’s sworn statement given on August 25, 1977, which indicated that he was 22 years old at that time.
Villar admitted under oath that Exhibit E was executed, contesting only the claim of his age in that document by asserting that he had provided his date of birth instead.

The defense’s Exhibit 1 was undermined by its late registration and lack of an accompanying explanation.
The testimonies from his siblings were considered unreliable since their own statements indicated the eldest was only 18 years old, casting doubt on their personal knowledge regarding Villar’s age.
The prosecution’s Exhibit E, given by Villar a day after the offense, was deemed to be more spontaneous and reliable in recounting his actual age at the time of the crime.

Whether the trial court erred in allowing Francisco Villar to introduce evidence establishing his minority as a privileged mitigating circumstance.

Should Exhibit 1—a Certificate of Live Birth recorded long after the fact—be afforded significant probative weight?
Can the testimonies of defense witnesses (his mother and siblings) be considered credible compared to contemporaneous evidence?

Whether the reconciliation of conflicting evidence regarding Villar’s age (the immediate sworn statement versus the delayed birth certificate and related testimonies) justifies a change in the classification of the mitigating circumstance (minority).

The proper interpretation of Article 410 of the Civil Code in evidentiary matters—specifically, whether the provision renders Exhibit 1 conclusive or merely prima facie evidence requiring further corroboration.