Title
People vs. Castillo y Gomez
Case
G.R. No. 139339
Decision Date
Jan 19, 2001
Manuel Castillo convicted of parricide for fatally assaulting his mother while intoxicated; affidavits of desistance dismissed, civil indemnity upheld.
parricide
conviction
eyewitness testimony
A

Case Summary (G.R. No. 139339)

Factual Background

The prosecution relied principally on the testimony of Maria Theresa Castillo (Theresa), who was MANUEL’s niece and a caretaker of her grandparents, Rosenda and her husband Emilio. Theresa testified that before Rosenda’s death they lived in MANUEL’s house in Bucana, Davao City, with MANUEL’s children, Rosabella and Rodel, and with Theresa caring for the aged couple.

Theresa narrated that on the early evening of 16 November 1994, she and her grandparents were at home while MANUEL was drinking liquor with his son. At about 10:00 p.m., MANUEL approached Rosenda, who was groping for a urine pan. Theresa stated that MANUEL kicked Rosenda several times, causing a cut on her right eyebrow and making her hit a piece of wood protruding from the corner of the house. She further testified that MANUEL continued assaulting Rosenda even after she began crawling and pleading for him to stop. MANUEL allegedly ceased the beating only after Theresa cried out and rushed to help Rosenda, who was by then seriously injured and dying. Theresa also testified that MANUEL arrived, blamed Rosenda for what had happened, and cradled his mother in his arms.

On the medical aspect of the incident, the prosecution presented Dr. Danilo P. Ledesma, a medico-legal officer who conducted an autopsy on Rosenda and prepared a necropsy report and death certificate. He found multiple injuries, including contusions and fractures on the left side of the face and left hand, severe brain hemorrhage, multiple fractures on the ribs, and laceration of both lungs, with blood in the left chest cavity. He explained that the contusions and fractures could have been caused by an undetermined number of blows, such as by the head being banged against a door or wall, or the chest being kicked or stepped upon. He identified the immediate cause of death as intracranial hemorrhage. On cross-examination, Dr. Ledesma declared that it was impossible for the deceased to have sustained the injuries—particularly the intracranial hemorrhage—by merely falling off her bed.

Anacorita Castillo B. Jayson (Anacorita), MANUEL’s older sister, testified that she initiated the complaint for parricide after learning of Rosenda’s death from MANUEL’s sons on 18 November 1994, and stated that her father did not file the complaint because he was sickly and had already died at the time she testified.

The defense presented witnesses to deny or cast doubt on MANUEL’s participation. Rodel Castillo testified that he and his family slept in the living room with no partition, owing to renovations. He denied any drinking spree with MANUEL and maintained that they had only a few shots of liquor because MANUEL liked to drink before bedtime. He claimed he noticed nothing unusual and testified that MANUEL woke them the next morning after discovering that their grandmother had died. He added that MANUEL bathed Rosenda’s body and called a funeral parlor. Rodel also stated that MANUEL was arrested at noon of 17 November 1994 on suspicion of killing Rosenda, though he initially did not know the reason for the arrest.

Josie Castillo, MANUEL’s common-law wife since 1979, corroborated much of Rodel’s account and added that she did not notice anything irregular about Rosenda’s corpse, which she said the family treated as a natural death. Josie also testified that Theresa later informed her that Fe Regalado, MANUEL’s legal wife, fetched and brought Theresa to the police station and prodded her to provide a statement, which Josie suggested was an act of retaliation against MANUEL. Josie further recounted that after Rosenda’s wake, Theresa supposedly confessed that Fe convinced her to tell the police that MANUEL killed Rosenda, and that Theresa had later been living with Fe until she was asked to leave.

Lisa Castillo, MANUEL’s daughter with Josie, described the house layout and testified that her grandparents slept in the middle of the house while she and her parents slept near the door, with MANUEL between them. She stated that on the evening of 16 November 1994, when MANUEL went to bed, her grandparents were already asleep. She then woke up at 6:00 a.m. and soon learned Rosenda had died. She stated that MANUEL was cleaning Rosenda when she discovered the death.

MANUEL himself admitted that he had been living separately from his legal wife Fe Regalado, and had been cohabiting with Josie since 1979. He testified that he was the sole provider for his parents and that Theresa took care of them, but he and Josie cleaned their parents when rumors suggested malodor. MANUEL stated that he returned home in the early evening of 16 November 1994, joined Rodel who was drinking and had two shots of liquor, and that by 8:00 p.m. he and Josie went to bed while his daughter remained awake. Upon waking at 4:00 a.m. of the following day, he noticed Rosenda’s color was different. He touched her and found her cold and dead. He claimed that Rosenda’s body emitted a foul smell so he cleaned her and woke the rest of the household, asking Theresa why she neglected Rosenda, to which Theresa replied that Rosenda was old and her death was inevitable. MANUEL then called the funeral parlor and arranged the funeral. He left the house, and on his return Theresa was no longer home. He stated that around noon the police arrested him based on a complaint filed against him, and that the police advised him to settle the case privately because it involved the family. He claimed that at the police station he saw Fe and his sister Anacorita, but the police prevented him from approaching them. He testified that no copy of the complaint was given to him and that counsel was not provided, and that he only realized he was charged with parricide when he later instructed Josie to obtain a copy of the complaint. He also testified that Theresa visited him in jail on New Year’s Day 1995 and asked for his forgiveness, saying Fe coached her on what to tell the police, and that Anacorita informed him that they had executed affidavits of desistance. MANUEL also testified that he had copies of those affidavits.

Trial Court Proceedings

After trial, the Regional Trial Court convicted MANUEL of parricide and sentenced him to reclusion perpetua with accessory penalties, and ordered him to pay costs. The trial court found beyond reasonable doubt that MANUEL mauled his mother, giving credence to Theresa’s eyewitness account. It held that Theresa had no improper motive to incriminate MANUEL and that any sermons the accused allegedly gave were not sufficient reason to disregard her testimony. The court also considered that the defense failed to confront prosecution witnesses Theresa and Anacorita with their respective affidavits of desistance executed before they testified, and it treated that omission as adverse to MANUEL. The trial court gave no weight to the affidavits of desistance and the joint affidavit executed by Anacorita and Salvador because none of the affiants was presented to attest to the truth of their allegations, and because Anacorita and Salvador were not eyewitnesses. Nonetheless, the trial court appreciated in favor of MANUEL the mitigating circumstance of lack of intent to commit so grave a wrong, reducing the effect of culpability in the matter of penalty adjustment. The trial court did not award civil indemnity, reasoning that the affidavits of desistance by Anacorita and Salvador constituted a waiver of civil liability, citing People vs. Renato Linsangan, Jr., et al., G.R. No. 95232 and 95592, January 31, 1992.

The Parties’ Contentions on Appeal

MANUEL appealed, assigning errors on the sufficiency of the prosecution evidence and on the trial court’s treatment of the affidavits of desistance in relation to civil liability.

On the first assigned error, MANUEL argued that Theresa’s testimony was insufficient and incredible because, if MANUEL had mauled Rosenda continuously for several hours from about 10:30 p.m. until 3:00 a.m., other occupants in the house should have been awakened and intervened. He also contended that the prosecution did not establish proof of any prior harm or animosity toward Rosenda. He further cited alleged inconsistencies between Theresa’s affidavit and her in-court testimony, including differences on when the assault began and on the amount of liquor consumed. For Anacorita’s affidavit, MANUEL maintained that it lacked personal knowledge because it allegedly merely repeated what MANUEL’s sons told her.

On the second assigned error, MANUEL asserted that the trial court erred by refusing to accord evidential weight to the affidavits of desistance while, in the same breath, absolving him from civil liability based on those affidavits. He argued that the prosecution did not object to the admission of the affidavits, and that efforts to produce the affiants as witnesses had proved futile because Theresa’s whereabouts was unknown, Anacorita died, and Salvador became bedridden. He claimed that subpoenas were returned unserved and that he had to present the prosecutors who received the affidavits. MANUEL thus sought a recognition that civil liability should not have been denied by reliance on the affidavits that allegedly lacked weight for criminal purposes.

Supreme Court Ruling

After reviewing the evidence, the Supreme Court affirmed MANUEL’s conviction for parricide with modification. The Court found MANUEL guilty beyond reasonable doubt, sustaining the trial court’s assessment of Theresa’s testimony and the consistency of the medical evidence with deliberate assault rather than natural or accidental death. The Supreme Court, however, corrected the trial court’s disposition on civil liability. It awarded P50,000 as civil indemnity to the heirs of Rosenda Castillo.

Legal Basis and Reasoning

The Supreme Court gave controlling weight to Theresa’s testimony. It held that Theresa’s account was unwavering and that she had no ill motive to testify against MANUEL, who was her uncle and benefactor. The Court emphasized

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