People vs. Delos Santos, Jr.

Parricide is established by proof that a person was killed, that the accused killed that person, and that the deceased is the accused's parent; the filial relationship may be proved by the accused's admission under oath and stipulation, even without a birth certificate, and a lone eyewitness's credible and positive identification can sustain conviction.

Appellant Paulino Delos Santos, Jr. is the son of the deceased Paulino Delos Santos, Sr., a relationship appellant admitted under oath and stipulated during pre-trial. The charge is parricide under Article 246 of the Revised Penal Code, which penalizes the killing of a parent by a child with reclusion perpetua to death. The prosecution's evidence included Michael L. San Gabriel, Dr. Virginia B. Mazo, and PO3 Gil V. Obog, while the defense presented appellant as its lone witness.

On May 8, 2011, around 11:30 in the evening, Michael L. San Gabriel was hanging out with Diego, Dante, Hennie, and Marcos Delos Santos in the house of his cousin Jovito Libanan in Purok 3, Macolabo Island, Paracale, Camarines Norte. Jovito was the common-law spouse of Liezel Delos Santos, a daughter of Paulino Delos Santos, Sr. While Michael and the others were laughing, singing, and having fun, appellant Paulino Delos Santos, Jr., armed with a knife, suddenly arrived and appeared to be intoxicated. He immediately engaged in a heated verbal argument with his brother Marcos. The noise awakened their father, Paulino, Sr., who prodded appellant to leave, but appellant refused. Appellant warned his father not to interfere and challenged him to a fight. While father and son were pushing each other, appellant suddenly stabbed Paulino, Sr. in the upper left side of the chest, causing the latter to fall to the ground. Appellant immediately fled, and Paulino, Sr. died even before he could be brought to the hospital.

Michael positively identified appellant during the trial as the person who stabbed and killed Paulino, Sr. PO3 Gil V. Obog testified that the police received a report about the stabbing incident involving appellant and Paulino, Sr.; he and the other police officers went to appellant's residence but did not find him there, so they proceeded to the house of Paulino, Sr. PO3 Obog knew appellant because the latter had been previously incarcerated for other cases. Dr. Virginia B. Mazo, the Municipal Health Officer of Paracale, Camarines Norte, issued the victim's death certificate indicating that the stab wound was the immediate cause of death.

Appellant denied killing his father. According to him, in the evening of May 8, 2011, he was awakened by a noise coming from the adjacent house of his brother-in-law Jovito. When he went outside to check, he saw Jovito with blood stains on his hands. He asked Jovito about the blood stains, but Jovito did not respond. He then heard someone from inside Jovito's house screaming that his father, Paulino, Sr., was already dead. He tried to get inside Jovito's house but was told to leave the place or he would be killed next.

The RTC found that the testimonies of the prosecution witnesses proved appellant killed his own father by stabbing him in the upper left side of the chest, and that appellant's alibi and denial must fail against his positive identification as the author of the crime. The CA found Michael's testimony straightforward, truthful, and credible.

• Credibility of the Lone Eyewitness: Appellant argued that the RTC erred in giving credence to Michael's testimony because it was unlikely that he would stab his own father without any apparent reason or motive, Michael failed to provide more specific details of the stabbing incident, and the other witnesses who were present at the crime scene did not testify during the trial.
• Reasonable Doubt: Appellant argued that the prosecution failed to prove his guilt beyond reasonable doubt and prayed for acquittal.

• Positive Identification: Respondent countered that Michael's straightforward testimony clearly established that appellant killed his father; lack of motive on appellant's part and lack of corroborative evidence, such as the testimonies of other witnesses present at the crime scene, do not diminish the weight of appellant's positive identification as the perpetrator of the crime.

• Sufficiency of Evidence — Parricide: Whether the CA erred in affirming appellant's conviction for parricide despite the alleged failure of the prosecution to prove guilt beyond reasonable doubt and the alleged credibility issues in Michael's lone testimony.

• Sufficiency of Evidence — Parricide: No. The SC affirmed with modification, holding that all the elements of parricide were established by appellant's admission of filiation and Michael's credible positive identification, and that the penalty and damages were properly imposed with modification.

• Sufficiency of Evidence — Parricide: The SC affirmed with modification. Article 246 defines parricide as killing one's father, mother, or child, whether legitimate or illegitimate, or any ascendant, descendant, or spouse, and penalizes it with reclusion perpetua to death. The SC ruled that parricide requires (1) a person is killed; (2) the accused is the killer; and (3) the deceased is either the legitimate spouse of the accused, or any legitimate or illegitimate parent, child, ascendant or descendant of the accused.
• Third element: The SC found the third element undisputed because appellant himself admitted and declared under oath that the deceased Paulino, Sr. is his father, and he also stipulated this fact during pre-trial. The absence of appellant's certificate of live birth did not negate culpability because oral evidence of the fact of filial relationship may be considered. In People vs. Ayuman, the accused admitted during trial that the victim was his son; although the victim's birth certificate was not presented, the SC considered the admission competent evidence and convicted him of parricide.
• First and second elements: The SC found that Michael positively and categorically identified appellant as the person who killed his father. Michael narrated in detail the events from appellant's arrival at the scene, drunk and armed with a knife, through the argument with his brother, the warning to his father not to interfere, the challenge to a fight, the pushing, and the stabbing in the upper left chest that caused Paulino, Sr. to fall and die. The fact that Michael did not specify the direction of the fatal blow or the type of bladed weapon did not affect his credibility because these were minor details; what mattered was his consistency on the essential elements and his positive, categorical identification of appellant.
• Lone eyewitness: The SC held that Michael's lone testimony, found positive, categorical, and credible, was sufficient to support conviction. Under People vs. Hillado, the testimony of a lone eyewitness, if found positive and credible by the trial court, is sufficient especially when it bears the earmarks of truth and sincerity and was delivered spontaneously, naturally, and in a straightforward manner. Witnesses are weighed, not numbered; evidence is assessed by quality, not quantity; corroboration is necessary only when there are reasons to suspect that the witness falsified the truth or that his observation was inaccurate.
• Physical evidence: Michael's testimony conformed with the physical evidence because the death certificate issued by Dr. Mazo showed that Paulino, Sr. sustained a single stab wound that caused his death.
• Motive: The SC held appellant could not truthfully claim he had no motive to kill his father. Michael testified that appellant appeared intoxicated and got into a heated argument with his brother; when their father stepped in and prodded appellant to leave, appellant resented it, warned his father not to interfere, and challenged him to a fight; they were pushing each other when appellant suddenly stabbed his father. In any event, proof of motive does not show guilt, but its absence does not establish innocence. Under People vs. Ducabo, motive is irrelevant when the accused has been positively identified by an eyewitness. Motive is not synonymous with intent and is neither proof nor an essential element of a crime. Michael was not shown to have been impelled by ill will to falsely impute parricide on appellant.
• Flight: Appellant's flight from the crime scene militated against his claim of innocence. The SC has held that the flight of an accused may be taken as evidence to establish guilt, for a truly innocent person would normally take the first available opportunity to defend himself and assert his innocence.
• Credibility deference: The evaluation of witness credibility and testimony is best undertaken by the RTC because of its unique opportunity to observe witnesses first hand and note their demeanor, conduct, and attitude under grueling examination. The SC deferred to the RTC's factual findings, especially since the CA fully concurred.
• Denial and alibi: Appellant's denial and alibi could not prevail over his positive identification. Denial and alibi are self-serving and deserve no weight when unsubstantiated by credible evidence. Appellant's admission that he was only six meters away from the crime scene even precluded the impossibility of him getting to the scene, committing the crime, and returning to his house thereafter.
• Penalty: The penalty for parricide is reclusion perpetua to death. With no aggravating or mitigating circumstance proven, both the RTC and the CA correctly sentenced appellant to reclusion perpetua. Under A.M. No. 15-08-02, the phrase "without eligibility for parole" is used only if the accused should have been sentenced to death had it not been for RA 9346. Here, appellant was sentenced to reclusion perpetua because no aggravating circumstance would have warranted death were it not for RA 9346, so the phrase need not be borne in the decision.
• Damages: The SC affirmed civil indemnity of ₱75,000.00. In accordance with prevailing jurisprudence, it increased moral and exemplary damages to ₱75,000.00 each. It awarded temperate damages of ₱50,000.00 in lieu of actual damages because the heirs suffered pecuniary loss although the exact amount was not proved. These amounts earn 6% interest per annum from finality until fully paid.

• Parricide elements — Parricide is committed when (1) a person is killed; (2) the accused is the killer; and (3) the deceased is either the legitimate spouse of the accused, or any legitimate or illegitimate parent, child, ascendant or descendant of the accused. The SC applied this test and found all three elements established.
• Filiation by admission — The filial relationship may be established by the accused's oral admission under oath and stipulation during pre-trial; a certificate of live birth is not indispensable. The SC applied this because appellant admitted and stipulated that Paulino, Sr. was his father.
• Lone eyewitness rule — A lone eyewitness's testimony, if positive and credible, is sufficient to support conviction; witnesses are weighed, not numbered, and corroboration is required only when there is reason to suspect falsification or inaccurate observation. The SC applied this to Michael's testimony.
• Motive not an element — Motive is not synonymous with intent and is neither proof nor an essential element of a crime; its absence does not establish innocence, and it is irrelevant when the accused is positively identified. The SC applied this despite appellant's claim of no motive.
• Flight as evidence of guilt — Flight may be taken as evidence of guilt because a truly innocent person would normally take the first opportunity to defend himself and assert innocence. The SC applied this to appellant's immediate flight from the crime scene.
• Denial and alibi — Denial and alibi are self-serving and cannot prevail over positive identification, especially when unsubstantiated; proximity to the scene may preclude the impossibility of committing the crime. The SC applied this to appellant's defense.
• Trial court deference on credibility — The RTC's credibility findings are accorded finality because it has the unique opportunity to observe witnesses' demeanor, conduct, and attitude, especially when the CA concurs. The SC applied this to Michael's testimony.
• Parole phrase under A.M. No. 15-08-02 — The phrase "without eligibility for parole" is used to qualify reclusion perpetua only if the accused should have been sentenced to death had it not been for RA 9346. The SC applied this and omitted the phrase because no aggravating circumstance warranted death.
• Damages in parricide — Civil indemnity, moral damages, exemplary damages, and temperate damages may be awarded; temperate damages replace actual damages when pecuniary loss is shown but the exact amount is not proved, and awards earn 6% interest from finality. The SC applied this by awarding ₱75,000.00 each for civil indemnity, moral, and exemplary damages, ₱50,000.00 temperate damages, and 6% interest.

• "Parricide is committed when (1) a person is killed; (2) the accused is the killer; and (3) the deceased is either the legitimate spouse of the accused, or any legitimate or illegitimate parent, child, ascendant or descendant of the accused." — The SC enumerates the elements of parricide, which it then applies to appellant's admission of filiation and Michael's identification.
• "Thus, the testimony of a lone eyewitness, if found positive and credible by the trial court, is sufficient to support a conviction especially when the testimony bears the earmarks of truth and sincerity and had been delivered spontaneously, naturally and in a straightforward manner." — The SC quotes People vs. Hillado to reject the need for corroboration and to sustain Michael's lone testimony.
• "Motive is not synonymous with intent. Motive alone is neither a proof nor an essential element of a crime." — The SC uses this to reject appellant's argument that the absence of motive should create reasonable doubt.
• "On countless occasions, the Court has held that the flight of an accused may be taken as evidence to establish his guilt." — The SC treats appellant's immediate flight from the crime scene as evidence militating against his claim of innocence.

• People vs. Andaya, G.R. No. 219110, April 25, 2018 — Relied on for the elements of parricide.
• People vs. Ayuman, 471 Phil. 167, 180 (2004) — Followed; admission of filiation during trial sufficed despite the absence of a birth certificate.
• People vs. Hillado, 367 Phil. 29 (1999) — Followed; a lone eyewitness's testimony, if positive and credible, is sufficient for conviction.
• People vs. Ducabo, 560 Phil. 709, 723-724 (2007) — Followed; motive is irrelevant when the accused has been positively identified by an eyewitness.
• People vs. Pentecostes, 820 Phil. 823, 839 (2017) — Followed; flight may be taken as evidence of guilt.
• People vs. Jugueta, 783 Phil. 806 (2016) — Followed for the amounts of civil indemnity, moral damages, exemplary damages, and temperate damages.
• People vs. Saltarin, G.R. No. 223715, June 3, 2019 — Followed; the phrase "without eligibility for parole" need not qualify reclusion perpetua where the death penalty would not have been imposed but for RA 9346.
• People vs. Gonzales, G.R. No. 217022, June 3, 2019 — Followed; monetary awards earn 6% interest per annum from finality until fully paid.

• Article 246, Revised Penal Code, as amended by Republic Act No. 7659 — Defines and penalizes parricide with reclusion perpetua to death. The SC applied it by affirming the conviction and imposing reclusion perpetua because no aggravating or mitigating circumstance was proven.
• Republic Act No. 9346 — Prohibits the imposition of the death penalty. The SC cited it in connection with A.M. No. 15-08-02, holding that the phrase "without eligibility for parole" is used only if the accused should have been sentenced to death had it not been for RA 9346; here, no aggravating circumstance warranted death, so the phrase was omitted.
• A.M. No. 15-08-02 — Guidelines for the Proper Use of the Phrase "Without Eligibility for Parole" in Indivisible Penalties. The SC applied it to hold that the phrase need not be borne in the decision to qualify appellant's reclusion perpetua.