Case Summary (G.R. No. L-54063)
Procedural History and Sentencing
Following his guilty plea, Villar was convicted of murder by the Court of First Instance of Rizal on March 30, 1979. The court sentenced him to reclusion perpetua, ordered him to indemnify the deceased victim's heirs with P12,000, and directed him to pay the costs associated with the trial. Villar's appeal raised one primary issue: the trial court's failure to consider his minority as a privileged mitigating circumstance.
Evidence of Minority
To establish his age, Villar presented a delayed certificate of live birth (Exhibit 1) which indicated his birth date as October 26, 1961. This certificate was submitted over 17 years after his purported birth. Villar's mother, Leonor Villar, testified regarding the birth certificate and provided additional context about his baptism. However, she had lost the baptismal certificate that could further substantiate Villar's claim.
Villar himself, along with his siblings, testified that he was born on October 26, 1961, and asserted that he was "only 15 years going to 16 years" at the time of the offense. However, the prosecution relied on Exhibit E, a sworn statement made by Villar shortly after the crime on August 25, 1977, where he claimed to be 22 years old.
Court’s Evaluation of Evidence
The court evaluated the evidence presented by Villar in support of his age claim, concluding that Exhibit 1 and the testimonies from his family were less credible than the sworn statement contained in Exhibit E. The trial court noted that the delayed registration of Villar's birth lacked sufficient justification, as it was filed long after the crime and under circumstances that raised doubts about its reliability.
The court further observed that the siblings' testimonies were inherently limited by their ages, and could not be regarded as informed accounts of Villar's birth. Conversely, Exhibit E was produced shortly after the commission of the crime, lending it greater credibility. The court was mindful that a voluntarily given statement, such as Exhibit E, carries significant weight in determining facts, including the individual's age at the time of the crime.
Legal Principles Applied
In reviewing the appeal, the court referred to Article 410 of the Civil Code, which affirms that documents in the
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Case Background
- The case was decided by the Second Division of the Supreme Court of the Philippines on July 24, 1981, under G.R. No. 54063.
- The case originated from the Court of First Instance of Rizal, where Francisco Villar and Angel San Andres were accused of murder (Criminal Case No. C-9146).
- The incident occurred on August 24, 1977, in Caloocan City, Metro-Manila, involving the fatal stabbing of Arturo C. Pineda.
- The prosecution alleged that both accused conspired to kill Pineda with treachery and evident premeditation.
Procedural History
- Angel San Andres was acquitted of the charges on June 27, 1979.
- Francisco Villar initially pleaded not guilty but changed his plea to guilty on January 16, 1979, after the prosecution rested its case.
- Villar's guilt was uncontested, as he admitted in his brief that there is no doubt regarding his role as the perpetrator.
Sentencing
- On March 30, 1979, Villar was sentenced to Reclusion Perpetua, ordered to indemnify the heirs of the victim with P12,000.00, and to pay the costs of the trial.
- Villar appealed the decision, citing a single assignment of error regarding the trial court's failure to consider his minority as a privileged mitigating circumstance.