G.R. No. 248929 - People vs. Delos Santos, Jr.

Case Summary (G.R. No. 248929)

Procedural History

The Information charged appellant with parricide for stabbing his father on May 8, 2011. The case was docketed as Criminal Case No. 14834 before the Regional Trial Court (Branch 39) in Daet, Camarines Norte; appellant pleaded not guilty. Following trial, the RTC convicted appellant. The Court of Appeals affirmed the conviction with a modification imposing six percent interest per annum on monetary awards. The appeal to the Supreme Court followed, with the parties adopting their briefs filed before the Court of Appeals.

Charge and Elements Alleged

The Information alleged that on the night of May 8, 2011, appellant, being the son of the victim and with intent to kill, with treachery and evident premeditation, attacked and stabbed his father in the upper left chest with a bladed weapon, inflicting a mortal wound that caused instantaneous death. The essential statutory elements of parricide under Article 246 are: (1) a person was killed; (2) the accused was the killer; and (3) the deceased was the accused’s parent (filial relationship).

Prosecution’s Factual Narrative

Prosecution witnesses, led by Michael, testified that on the night of the incident several persons were at Jovito Libanan’s house when appellant arrived intoxicated and armed with a knife. Appellant allegedly engaged in a heated argument with his brother Marcos, the father intervened and told appellant to leave, appellant warned his father not to interfere, a physical confrontation followed, and appellant suddenly stabbed the father in the upper left chest, causing him to fall and die. Michael positively identified appellant as the assailant. PO3 Obog testified regarding the police response and that appellant was absent from his residence when officers searched. Dr. Mazo issued a death certificate indicating the stab wound as the immediate cause of death.

Defense Factual Narrative

Appellant testified that he did not kill his father. He described being awakened by noise at Jovito’s house, observing Jovito with blood-stained hands, and hearing a scream that his father was dead. He asserted he was prevented from entering Jovito’s house and was warned to leave or be killed. Appellant presented this account as an alibi/denial of culpability.

Trial Court Findings and Sentence

The trial court found all elements of parricide proven beyond reasonable doubt, credited the positive identification by Michael, rejected appellant’s alibi and denial, and convicted appellant of parricide. The RTC sentenced appellant to reclusion perpetua (stated “without eligibility for parole” in its decision) and awarded P75,000.00 as civil indemnity, P50,000.00 as moral damages, and P30,000.00 as exemplary damages to the heirs.

Court of Appeals Disposition

The Court of Appeals affirmed the RTC’s conviction but modified the monetary awards to carry legal interest at six percent per annum from the finality of its decision until full payment. The CA thereby affirmed both the conviction and the trial court’s factual credibility determinations.

Issue on Appeal to the Supreme Court

The central issue presented to the Supreme Court was whether the Court of Appeals erred in affirming appellant’s conviction for parricide — essentially a review of whether the evidence, particularly the lone eyewitness testimony and attendant circumstances, established guilt beyond reasonable doubt.

Supreme Court’s Findings on Guilt and Evidentiary Weight

The Supreme Court affirmed the conviction with modification. It confirmed the third statutory element (filial relationship) was undisputed because appellant admitted the victim was his father and stipulated the fact at pre-trial; the absence of a birth certificate did not negate filiation since oral admission may suffice. The Court accepted Michael’s testimony as positive, categorical and credible, emphasizing: (a) Michael’s detailed narrative of events leading to the stabbing; (b) alignment of the eyewitness testimony with physical evidence (death certificate showing a single stab wound to the chest); (c) legal precedent that a lone credible eyewitness is sufficient to support conviction when the testimony bears the earmarks of truth and is not shown to be fabricated (citing People v. Hillado and related authorities cited in the decision); (d) the presence of a motive or basis for confrontation (appellant’s intoxication and argument) and the Court’s reiteration that the absence of motive does not exonerate an accused when identification is positive; (e) lack of demonstrated ill will or reason for the eyewitness to falsely accuse appellant; and (f) appellant’s flight from the scene as circumstantial evidence consistent with guilt. The Supreme Court deferred to the trial court’s credibility determinations, noting the trial court’s superior opportunity to observe witnesses firsthand and the concurrence of the Court of Appeals.

Assessment of Alibi and Proximity Evidence

The Court found appellant’s alibi and denial unavailing against the positive

Case Syllabus (G.R. No. 248929)

The Case — Procedural Posture and Relief Sought

Appeal from the Court of Appeals Decision dated June 28, 2018 in CA-G.R. CR-HC No. 08894, which affirmed the Regional Trial Court, Branch 39, Daet, Camarines Norte, Criminal Case No. 14834 conviction of Paulino Delos Santos, Jr. alias "Skylab" for parricide.
Appellant filed Notice of Appeal dated July 16, 2018 from the Court of Appeals decision.
The Court of Appeals affirmed the trial court's conviction but modified the monetary awards to carry legal interest of six percent (6%) per annum from finality of the decision until full payment.
Appellant seeks affirmative relief from the Supreme Court and prays anew for his acquittal; both parties adopted their briefs filed before the Court of Appeals in lieu of supplemental briefs pursuant to the Supreme Court Resolution dated October 16, 2019.

The Charge — Information Alleging Parricide

Information charged: on or about 11:30 o'clock in the evening of May 8, 2011 at Purok 2, Barangay Macolabo Island, Municipality of Paracale, Province of Camarines Norte, appellant, being the son of Paulino Delos Santos Sr., with intent to kill, with treachery and evident premeditation, did attack, assault and stab his father using a bladed weapon, inflicting a mortal wound on the chest causing instantaneous death, to the damage and prejudice of the heirs of the victim, contrary to law.
Case was raffled to Regional Trial Court‑Daet, Camarines Norte, Branch 39 and docketed as Criminal Case No. 14834.
On arraignment, appellant pleaded "not guilty."

Trial Court Proceedings — Participants and Testimony

Prosecution witnesses: Michael L. San Gabriel (referred to as Michael), Dr. Virginia B. Mazo (Municipal Health Officer), and Police Officer 3 Gil V. Obog (PO3 Obog).
Defense evidence: appellant testified as the lone witness for the defense.
Trial court presided over the case and issued a Decision dated September 5, 2016 (penned by Judge Winston S. Racoma).

Prosecution's Version — Facts as Presented at Trial

On May 8, 2011, around 11:30 p.m., Michael was at the house of his cousin Jovito Libanan in Purok 3, Macolabo Island, Paracale; Jovito is the common-law spouse of Liezel Delos Santos, daughter of the victim Paulino Sr.
Present at Jovito's house were Michael, Diego, Dante, Hennie (reported in another passage as "Hermie"), and Marcos Delos Santos (Marcos); they were laughing, singing, and having fun.
Appellant suddenly arrived appearing to be intoxicated and armed with a knife; he instantly engaged in a heated verbal argument with his brother Marcos, which awakened the victim Paulino Sr.
The victim prodded appellant to leave; appellant refused, warned his father not to interfere, and challenged him to a fight.
While pushing each other, appellant suddenly stabbed Paulino Sr. in the upper left side of the chest, causing the victim to fall to the ground; appellant immediately fled.
Paulino Sr. died even before being brought to the hospital.
Michael positively identified appellant as the person who stabbed and killed his father.
PO3 Obog testified that police received a report of the stabbing, went to appellant's residence (but did not find him), then proceeded to the house of the victim; PO3 Obog knew appellant from a prior incarceration for other cases.
Dr. Mazo issued the victim's death certificate indicating that the stab wound was the immediate cause of death.

Defense's Version — Appellant's Testimony and Alibi

Appellant denied killing his father.
Appellant testified that he was awakened by a noise from the adjacent house of his brother-in-law Jovito; he saw Jovito with blood stains on his hands but Jovito did not respond to questions.
Appellant heard someone inside Jovito's house screaming that his father Paulino Sr. was already dead.
When appellant tried to enter Jovito's house, he was told to leave and warned he would be killed next if he did not leave.
Appellant maintained he had not committed the killing.

Trial Court's Ruling (September 5, 2016)

Trial court found appellant guilty beyond reasonable doubt of parricide and sentenced him to reclusion perpetua, "without eligibility of parole" (as reflected in the trial court decision).
Ordered appellant to pay heirs of the victim: PhP75,000.00 as civil indemnity, PhP50,000.00 as moral damages, and PhP30,000.00 as exemplary damages.
Trial court found all elements of parricide established: that the victim was killed, the accused was the killer, and the deceased was the accused's father.
Trial court accorded full credence to the prosecution witnesses, particularly Michael's positive identification, and rejected appellant's alibi and denial.

Proceedings Before the Court of Appeals

Appellant argued the trial court erred by giving credence to Michael's testimony because: (1) it was unlikely appellant would stab his father without reason or motive; (2) Michael failed to provide more specific details of the stabbing; and (3) other witnesses present at the crime scene did not testify.
The Office of the Solicitor General argued Michael's straightforward testimony established guilt; lack of motive or corroborative witnesses did not diminish the weight of positive eyewitness identification.
Court of Appeals, in a Deci