Case Summary (G.R. No. 177218)
Overview of Proceedings
Noel T. Sales was convicted of parricide and slight physical injuries after the death of his legitimate eldest son, Noemar Sales, and the infliction of injuries on his younger son, Noel Sales Jr. The allegations stemmed from an incident on September 20, 2002, during which Noel T. Sales allegedly beat his sons as a form of discipline, resulting in Noemar's death and Junior's injuries.
Allegations and Charges
The charge of parricide claimed that on September 20, 2002, with evident premeditation and in a fit of anger, Noel T. Sales struck Noemar multiple times with a piece of wood, causing fatal injuries. Concurrently, a separate Information charged him with slight physical injuries for physically assaulting Junior, which required medical attention.
Trial and Testimonies
During the trial, the prosecution presented testimonies indicating that the children had left the house without permission and were subsequently subjected to severe beating by the appellant. The defense, however, contended that the discipline imposed was not intended to be fatal and that Noemar's existing health condition (notably a weak heart and epilepsy) caused his death, rather than the actions of the appellant.
Ruling of the Regional Trial Court
The Regional Trial Court ruled that the prosecution had met the burden of proof for both charges, convicting Noel T. Sales. The court disregarded the aggravating circumstance of evident premeditation but acknowledged mitigating circumstances, including voluntary surrender and lack of intent to commit such a grave wrong. The appellant was sentenced to reclusion perpetua for parricide and received a sentence of twenty days of arresto menor for the slight physical injuries inflicted on Junior.
Appeal to the Court of Appeals
Noel T. Sales appealed, arguing that the trial court erred in conviction and in its evaluation of testimony. However, the Court of Appeals affirmed the lower court's decision, concluding that there was sufficient evidence as presented by the prosecution and that the defenses put forth were unconvincing.
Supreme Court's Ruling on the Appeal
The Supreme Court upheld the appellate court's decision, reiterating several significant points. It emphasized that parental discipline must be exercised within reasonable bounds and that the actions taken by the appellant deviated into the realm of sadism rather than corrective discipline. The Court concluded that all elements of the crime of parricide—as defined under Article 246 of the Revised Penal Code—were satisfied: a child was killed by the appellant, who is the father.
Mitigating and Aggravating Circumstances
While recognizing voluntary surrender as a mitigating factor, the Supreme Court ruled that there was no basis for applying the mitigating circumstance of lack of intent to co
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Background of the Case
- Appellant Noel T. Sales was charged with parricide and slight physical injuries against his two minor sons, Noemar Sales and Noel Sales, Jr.
- Incident took place on September 20, 2002, in Barangay San Vicente, Tinambac, Camarines Sur.
- Appellant pleaded not guilty to the charges.
- Case was consolidated and proceeded to trial after pre-trial stipulations.
Facts as Presented by the Prosecution
- Noemar (9 years old) and Junior (8 years old) left home without permission to attend a religious procession and did not return until the following day.
- Upon their return, appellant confronted the boys angrily and beat them with a stick, which broke during the beating.
- The boys were tied by hands and feet to a coconut tree and were continuously beaten with a thick piece of wood by appellant.
- Maria Litan Sales, the mother, remained inside due to fear for her life.
- Noemar showed visible injuries including a cracked head and wounds on legs before collapsing and losing consciousness.
- Despite efforts, Noemar was declared dead by a quack doctor and was buried the next day without official medical examination.
Version of the Defense
- Appellant claimed prior incidents where children left home without permission but were only scolded, not harmed.
- On the incident date, appellant admitted whipping his sons with a stick as disciplinary action but denied causing Noemar's death.
- Asserted Noemar had a weak heart and died from breathing difficulty, not physical injuries.
- Defense argued the boys left home multiple times and stole a pedicab, causing distress to appellant.
- Appellant sought medical help but no vehicle was available. Noemar died during waiting period.
- Testimony conflicted with maternal witness who stated Noemar suffered epilepsy.
Ruling of the Regional Trial Court (RTC)
- RTC found appellant guilty of parricide and slight physical injuries beyond reasonable do