G.R. No. 113791 ; February 22, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO MENDOZA, accused-appellant.

FACTS

Accused-appellant Rolando Mendoza was charged with the parricide of his wife, Maria Gina Avila Mendoza, on November 22, 1989, in Balasing, Sta. Maria, Bulacan. The prosecution alleged that he doused her with kerosene and set her on fire inside their home. The victim suffered extensive burns and died days later. The primary eyewitness was their five-year-old son, Paul Michael. During his initial testimony, the child stated his father boxed and tied his mother but became unresponsive to further questions. In a subsequent rebuttal, he categorically testified that his drunken father tied his mother, poured kerosene on her, and lit her on fire following a quarrel.
The defense presented a different narrative. Mendoza claimed he was asleep and awoke to find his wife already burning. He asserted he tried to extinguish the flames and rushed her to the hospital. He explained his absence during the wake and burial by stating he was distraught and hiding due to shame. The trial court convicted Mendoza of parricide, sentencing him to reclusion perpetua. He appealed, challenging the credibility and competency of his young son’s testimony.

ISSUE

The core issue is whether the testimony of the five-year-old child witness, Paul Michael, is credible and competent to sustain a conviction for parricide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the competency and credibility of a child witness. The Court held that under the Rules of Court, a child is competent to testify if they can perceive and make their perception known. Age alone does not disqualify a witness. The trial court diligently conducted a competency examination, observing the child’s demeanor and ability to distinguish truth from falsehood, and properly found him qualified.
Regarding credibility, the Court found the child’s testimony clear and convincing. His initial hesitation and subsequent detailed account were consistent with a traumatic experience. His identification of his father as the perpetrator was straightforward. The Court noted that the child’s testimony was corroborated by physical evidence, such as the kerosene bottle and burned items at the scene, and by the accused’s flight and absence after the incident, which indicated guilt. The defense of denial and alibi was weak and could not overcome the positive identification. The Court modified the decision to award civil indemnity to the victim’s heirs but upheld the penalty of reclusion perpetua.