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People vs. Castillo

The conviction of Domingo Castillo, Jr. for parricide was affirmed with modification. The accused ran over his father, Domingo Castillo, Sr., with a pickup truck after an argument near their home in Angat, Bulacan, and claimed the incident was accidental — the result of inadvertently stepping hard on the gas pedal. Eyewitness testimony, however, showed that the accused backed up the vehicle to gain momentum, accelerated at high speed into the victim who was standing in front, then reversed to run over him a second time, and walked away without rendering aid. The Court found these circumstances inconsistent with reckless imprudence and indicative of deliberate intent to kill. The award of P250,000 in actual damages was deleted for lack of proof, and moral damages of P50,000 were awarded in lieu thereof.

Primary Holding

Deliberate intent to do an unlawful act is essentially inconsistent with the idea of reckless imprudence, such that where the accused backed up his vehicle to gain momentum, accelerated at high speed into the victim standing in front, then reversed to run him over a second time, and walked away without summoning aid, the killing constitutes parricide committed with intent rather than homicide through reckless imprudence.

Background

Domingo Castillo, Jr. was the only son of Domingo Castillo, Sr., a well-to-do resident of Angat, Bulacan who operated a recapping shop on his premises. The appellant had never held a day's job in his life and, despite having a family of his own, continued to depend entirely on his parents for support. Several days before the incident, the father had a "heart to heart talk" with the appellant, asking him whether he would never change and urging him to seek employment. The case is governed by Article 246 of the Revised Penal Code, which punishes the killing of one's father, mother, child, ascendant, descendant, or spouse with the penalty of reclusion perpetua to death.

History

  1. Information for parricide filed before the RTC of Bulacan after NBI investigation confirmed foul play, following inquiries by the victim's daughter, Leslie C. Padilla, who suspected the death was not accidental.

  2. RTC Branch 14, Bulacan, April 6, 1995 — convicted the appellant of parricide beyond reasonable doubt, sentenced him to reclusion perpetua, and ordered him to pay P250,000 as actual damages to the other heirs of the victim.

  3. Supreme Court, Third Division, July 21, 1997 — affirmed the conviction with modification, deleting the award of actual damages for lack of proof and awarding P50,000 as moral damages instead.

Facts

On November 6, 1993, between 7:30 and 8:30 in the evening, Domingo Castillo, Jr. was drinking beer with his father, Domingo Castillo, Sr., at the D & G Restaurant in Norzagaray, Bulacan. After roughly two hours, a group of noisy customers arrived. Aware of his son's propensity for getting into fights, the elder Castillo urged the appellant to go home with him. The two boarded a blue pickup truck with plate number CBE 591, with the appellant driving and the victim in the passenger seat, heading toward their home in Angat, Bulacan. Both were by then somewhat intoxicated. During the trip, an argument ensued because the appellant kept insisting on returning to the restaurant while the father prevented him from doing so.

Upon nearing their house, the appellant abruptly stopped the pickup and the victim alighted. Holding a bottle of beer in his right hand, the victim raised both hands, stood in front of the vehicle, and said, "sige kung gusto mo sagasaan mo ako, hindi ka makakaalis" (go ahead, run over me if you want to leave). The appellant slowly drove the pickup forward, threatening to run over his father, prompting the victim to exclaim, "papatayin mo ba ako?" (are you going to kill me?). At that moment, prosecution eyewitness Ma. Cecilia Mariano was conversing with friends and a sister in an owner-type jeep parked at the side of the road. She testified that after the victim uttered those words, the appellant backed up the pickup — nearly hitting the jeep — and then drove forward at high speed, striking the victim. Not satisfied, the appellant put the vehicle in reverse, running over the victim a second time. He then alighted and walked toward their house.

Another witness, Arthur Agaran, who worked at the victim's recapping shop and was inside the residence changing clothes at the time, saw the pickup moving forward and backward about four times, approximately twenty to thirty meters from the house. When Agaran and another worker went outside to investigate, they found the victim's body bloodied and sprawled on the ground, with tire marks visible on his feet. They rushed the victim to the Dolorosa Hospital in Norzagaray, where he expired shortly thereafter.

The appellant initially passed off the death as an accident and was not immediately prosecuted. When his older sister, Leslie C. Padilla, arrived from the United States for the wake and funeral, she received different versions of the incident, some insinuating foul play. She engaged the National Bureau of Investigation, whose findings confirmed her suspicions and led to the filing of an information for parricide. The appellant did not dispute that he had run over his father but claimed he had accidentally stepped on the gas pedal forcefully, causing the vehicle to travel at fast speed without any intent to kill. The trial court, relying on the testimonies of Mariano and Agaran, found the appellant guilty beyond reasonable doubt of parricide.

Arguments of the Petitioners

  • Reckless Imprudence: The appellant argued that the parricide was committed through reckless imprudence, claiming there was no intention on his part to kill his father. He maintained that he had accidentally stepped on the gas pedal forcefully, causing the vehicle to travel at a fast speed.
  • Lack of Malice: The appellant asserted that the incident was an accident, implying the absence of malice or criminal intent required to constitute intentional parricide.

Issues

  • Intent vs. Reckless Imprudence: Whether the parricide was committed through reckless imprudence as claimed by the appellant, or with deliberate intent to kill.

Ruling

  • Intent vs. Reckless Imprudence: No. The parricide was committed with deliberate intent, not reckless imprudence. A deliberate intent to do an unlawful act is essentially inconsistent with the idea of reckless imprudence, and the circumstances of the killing — backing up to gain momentum, accelerating at high speed, reversing to run over the victim again, and walking away without rendering aid — demonstrated intentional killing.

Ruling Rationale

  • Intent vs. Reckless Imprudence: The Court applied the principle that deliberate intent to do an unlawful act is essentially inconsistent with reckless imprudence, the latter being characterized by the lack of malice or criminal intent in the execution of the act. In criminal negligence, the injury caused to another is unintentional, being merely the incident of another act done without malice but with lack of foresight, carelessness, or negligence. The prosecution established the three elements of parricide: (1) the death of the deceased; (2) that he was killed by the accused; and (3) that the deceased was the legitimate father of the accused. The appellant did not dispute that he ran over his father but claimed accident. The Court found this claim unworthy of credence based on several circumstances. First, eyewitness Mariano testified that prior to hitting the victim, the appellant was "intimidating" him by moving the pickup forward, prompting the victim to ask, "papatayin mo ba ako?" The appellant then backed up to gain momentum and accelerated at very fast speed, knowing the victim was still standing in front. Second, after the impact, instead of alighting to render aid — the normal reaction of a person who had accidentally run over another — the appellant reversed, running over the victim a second time, which explained the tire marks on the victim's feet observed by Agaran. Third, the appellant deliberately failed to promptly summon help. Mariano testified that after running over the victim, the appellant alighted and walked toward the town proper, leaving the vehicle in the middle of the street. Agaran confirmed that the appellant merely looked at him and the other workers as he passed the recapping shop. The appellant's claim that he shouted for help was found to be a fabrication. Fourth, the appellant's own testimony revealed a degree of enmity and resentment in his relationship with his parents: he had never worked, relied entirely on parental support, and had quarreled with his father, who days earlier had urged him to find employment. The Court also deferred to the trial court's assessment of witness credibility, applying the rule that appellate courts give great weight and highest respect to trial court findings on credibility, as the latter are in a better position to observe witness demeanor. The Court concluded that evidence, to be believed, must not only proceed from a credible witness but must be credible in itself — such as common experience and observation of mankind can approve as probable under the circumstances.

Doctrines

  • Distinction Between Intentional Felony and Reckless Imprudence — What qualifies an act as one of reckless or simple negligence or imprudence is the lack of malice or criminal intent in the execution thereof. In criminal negligence, the injury caused to another should be unintentional, being simply the incident of another act done without malice but with lack of foresight, carelessness, or negligence. Deliberate intent to do an unlawful act is essentially inconsistent with the idea of reckless imprudence. The Court applied this doctrine to reject the appellant's claim of accident, finding that his act of backing up to gain momentum, accelerating at high speed into the victim, reversing to run over him again, and walking away without aid all demonstrated deliberate intent.

  • Trial Court's Credibility Findings — In the matter of credibility of witnesses, the appellate court gives great weight and the highest degree of respect to the findings of the trial court, as the latter are in a better position to examine real evidence and observe the demeanor of witnesses. The Court relied on this doctrine to affirm the trial court's reliance on the testimonies of prosecution witnesses Mariano and Agaran.

  • Credibility of Evidence — Evidence, to be believed, must not only proceed from the mouth of a credible witness, but must be credible in itself — such as the common experience and observation of mankind can approve as probable under the circumstances. The Court invoked this principle to reject the appellant's version of events as inherently implausible.

Key Excerpts

  • "What qualifies an act as one of reckless or simple negligence or imprudence is the lack of malice or criminal intent in the execution thereof." — This passage articulates the doctrinal distinction between intentional felonies and culpable felonies (reckless imprudence), which the Court applied to reject the appellant's defense of accident.

  • "A deliberate intent to do an unlawful act is essentially inconsistent with the idea of reckless imprudence." — This formulation, drawn from precedent, establishes the controlling principle that intent and negligence are mutually exclusive categories, and serves as the ratio decidendi for affirming the parricide conviction.

  • "Evidence, to be believed, must not only proceed from the mouth of a credible witness, but it must be credible in itself — such as the common experience and observation of mankind can approve as probable under the circumstances." — This passage states the dual requirement for credible evidence and was invoked to reject the appellant's claim that he had shouted for help, which the Court found to be a fabrication inconsistent with human behavior.

Precedents Cited

  • People vs. Embalido, 58 Phil 154 (1933) — Cited for the elements of parricide under Article 246 of the Revised Penal Code.
  • People vs. Oanis, 74 Phil 257 (1943) — Cited for the principle that deliberate intent to do an unlawful act is essentially inconsistent with reckless imprudence, and that in criminal negligence the injury caused is unintentional.
  • United States vs. Maleza, 14 Phil 468 (1909) — Cited for the definition of reckless or simple negligence as characterized by the lack of malice or criminal intent.
  • Lee Eng Hong vs. Court of Appeals, 241 SCRA 392 (1995) — Cited for the rule on the great weight and respect accorded to trial court findings on witness credibility, and for the principle that evidence must be credible in itself.

Provisions

  • Article 246, Revised Penal Code — Defines and punishes parricide: any person who shall kill his father, mother, or child, whether legitimate or illegitimate, or any of his ascendants or descendants, or his spouse, shall be guilty of parricide and shall be punished by the penalty of reclusion perpetua to death. The provision was applied to convict the appellant, who killed his legitimate father.

Notable Concurring Opinions

Narvasa, C.J., Davide, Jr., Melo, and Paganiban, JJ., concurred.