G.R. No. L-32104 - People vs. Villaver

The case involves the People of the Philippines as the plaintiff-appellee and Narciso Villaver as the defendant-appellant.
Appellant Narciso Villaver, a father of eight (8) children, is accused of the crime of parricide involving his now deceased daughter, Francisca Villaver.

On the morning of September 24, 1965, Francisca Villaver, along with a group of eight persons that included her father and Genara Sordillo, went to the beach to bathe and collect shells.
After lunch, the appellant took his daughter to a mangrove swamp approximately 50 meters from the seashore.
Shortly thereafter, Francisca was seen running back from the mangrove with an uneasy appearance and a torn dress on the left side. She confided to Genara that her father had intentions of abusing her.
In the evening, around 7:00 PM, the appellant allegedly forced his daughter to ingest “Endrin,” a liquid pesticide used to kill worms in ricefields.

He is said to have grabbed her hair with one hand and, with the other, forced her mouth open to pour the poison in.
The act was directly witnessed by Remedios Villaver, a minor and younger sister of the victim, while the victim’s mother was occupied in another room nursing a baby.

Francisca was rushed to the hospital where she received emergency treatment; however, she died within 25 minutes of arrival due to chemical poisoning.

Remedios, though only sixteen years old at the time, testified that her father forcibly made her sister drink “Endrin.”
Her account detailed that her father took hold of Francisca’s hair and forced her mouth open while pouring the poison, an event she witnessed firsthand.

Genara Sordillo testified that she heard Remedios shouting for help from the appellant’s house.
Shortly afterward, Remedios, accompanied by two brothers, arrived at Genara’s house crying and explaining that Francisca had been forced to ingest “Endrin” by her father.
The defense’s claim of Genara’s alleged ulterior motive was rebutted by noting that her presence on the morning outing, alongside a direct correlation with other testimony, invalidated any such suggestion.

Upon arresting the appellant at his house, Corporal Bermudo obtained an admission from Narciso Villaver that he had indeed poisoned his daughter.
The officer also identified the bottle of “Endrin” used in the poisoning, which was corroborated by the appellant’s own acknowledgment.

Appellant’s account contended that after supper, Francisca ascended to the sala and voluntarily drank “Endrin” from a bottle he recognized as containing the poisonous liquid.
He claimed that he attempted to grab the bottle and chase after her when she jumped out the window but failed to intercept her, suggesting that his role was limited to an unsuccessful effort to stop her from drinking the liquid.
This defense was challenged by the consistent and direct testimonies of the witnesses, including the minor Remedios, who recounted the forceful manner in which the act was carried out.

Whether the testimony of a minor witness, Remedios Villaver, should be given full credence despite her young age and alleged inconsistencies.
The impact of corroborative testimony by Genara Sordillo on establishing the sequence of events.

Whether the evidence supports that the appellant intentionally and forcibly administered a poison to his daughter, thereby fulfilling the elements of parricide.
Whether the claim that Francisca voluntarily drank “Endrin” can be given any merit in light of the evidence.

Whether the crime was committed with evident premeditation and deliberate immoral intent necessary to elevate the crime under aggravating circumstances.
The legal appropriateness of applying any aggravating circumstances (such as the use of poison) under the Revised Penal Code.

Whether the lower court erred in convicting the appellant on the basis of the witness testimonies.
Whether the death penalty should be imposed given the nature of the crime or if a modification of penalty is warranted.