Case Summary (G.R. No. 125468)
Criminal Cases and Conviction
Three separate criminal cases were filed: Criminal Case No. 22 for parricide (the death of Salvacion Grulla), Criminal Case No. 23 for murder (the death of Consolacion Belmonte Grulla), and Criminal Case No. 29 for frustrated murder (injury inflicted on Natividad Grulla). The trial court sentenced Sto. Tomas to penalties and damages including reclusion temporal for parricide and an indeterminate penalty for murder, as well as damages awarded to the heirs of the deceased and the injured party.
Grounds for Appeal
Sto. Tomas appealed his conviction, asserting numerous errors by the trial court, including the recognition of Salvacion as his lawful wife, the finding of treachery, and the assessment of aggravating circumstances. He also contested the credibility of witnesses and the imposition of damages, claiming a lack of solid evidence to support the convictions.
Prosecution's Narrative
The prosecution’s version reveals that on the night of May 23, 1967, Sto. Tomas confronted his wife, seeking to take her and their children to Legaspi City. The situation escalated when Salvacion refused and an argument ensued, ultimately resulting in Sto. Tomas firing multiple shots, killing his wife and mother-in-law and injuring Natividad. Witness testimonies describe the shooting as deliberate.
Defense’s Account
Sto. Tomas argued that the victims’ injuries resulted from an accidental firing during a struggle over his firearm. He claimed that during a heated altercation with his mother-in-law, Salvacion accidentally shot Consolacion, and in the ensuing chaos, additional shots were fired unintentionally. However, forensic evidence disputed this narrative, detailing multiple gunshot wounds that suggested a calculated attack rather than an accident.
Credibility of Witnesses
Natividad Grulla’s testimony played a crucial role in the prosecution's case. She recounted witnessing Sto. Tomas shoot his wife, providing clear and consistent accounts throughout her testimony, which remained unscathed under cross-examination. Her account confirmed the deliberate nature of the shootings, undermining Sto. Tomas's assertions of accidental firing.
Forensic Evidence and Findings
The autopsy results indicated multiple gunshot wounds on both Salvacion and Consolacion, reflecting a deliberate attack rather than stray shots from an accidental discharge. Natividad’s severe injuries were also corroborated by medical evidence, which highlighted the permanent nature of her deformity, thus supporting the prosecution's argument for treachery and intentionality in Sto. Tomas’s actions.
Legal Assessment of Convictions
The trial court upheld the convictions, determining that the circumstances met the definitions for parricide and murder. Despite Sto. Tomas’s claims regarding the validity of his marriage to Salvacion, which he argued was void due to a previous marriage, the court adhered to the best evidence rule in dismissing such claims. Consequently, the absence of credible evidence from the defense did not suffice to alter the court's conviction.
Modifications
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Case Overview
- This case involves the tragic shooting incident that occurred on May 23, 1967, at the residence of the Grulla family in Donsol, Sorsogon.
- The shooting resulted in the deaths of Salvacion Grulla (the wife of the accused) and her mother, Consolacion Belmonte Grulla, while Natividad Grulla (the sister-in-law of the accused) survived but was seriously injured.
Background of the Incident
- The shooting took place at approximately 10:00 PM when the accused, Pacito Sto. Tomas, arrived at the Grulla residence intending to take his wife and children to Legaspi City.
- A heated argument ensued between Pacito and his wife, Salvacion, regarding her unwillingness to leave with him due to his past jealous behavior.
- During the argument, Pacito shot both Salvacion and Consolacion, resulting in their deaths, while Natividad was also shot when she attempted to escape.
Charges and Trial Proceedings
- Three criminal cases were filed against Pacito Sto. Tomas:
- Criminal Case No. 22: Parricide for the death of Salvacion Grulla.
- Criminal Case No. 23: Murder for the death of Consolacion Belmonte Grulla.
- Criminal Case No. 29: Frustrated murder for the near-fatal injury of Natividad Grulla.
- The accused pleaded not guilty to all charges, claiming the shootings were accidental.
Rulings of the Trial Court
- The trial court convicted Pacito Sto. Tomas on all counts, imposing various penalties and damages:
- Criminal Case No. 22: Sentenced to reclusion temporal and ordered to pay P15,000.00 to the heirs of Salvacion and P10,000.00 for moral damages.
- Criminal Case N