G.R. No. 141187; April 28, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. RONNIE MACTAL y AZARCON, appellant.

FACTS

Appellant Ronnie Mactal was charged with the parricide of his wife, Evelyn. The prosecution’s case was built on circumstantial evidence. Witnesses testified that on the night of July 14, 1995, the couple was heard arguing. Later, around 1:00 a.m., Alfred Young saw Evelyn seated lifelessly near a window with appellant standing close by, who then disappeared upon seeing a tricycle. Almost simultaneously, Romeo Adayo saw appellant carrying Evelyn’s body over his shoulder, walking briskly towards a dark street. Evelyn’s body was discovered hours later. Bloodstains were found in their house and on appellant’s clothing. The autopsy concluded death was due to a head injury caused by a blunt object.
The defense presented an alibi, with appellant claiming he was asleep at the time of the incident and denying the witnesses’ accounts. He was supported by testimonies from his son and mother stating he loved his wife and could not have killed her. The Regional Trial Court convicted appellant of parricide and, finding the aggravating circumstances of nighttime and abuse of superior strength, imposed the death penalty.

ISSUE

Whether the trial court erred in convicting appellant of parricide based on circumstantial evidence and in appreciating aggravating circumstances to justify the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The totality of the circumstantial evidence sufficed to establish guilt beyond reasonable doubt. The evidence presented—the couple’s violent history, the eyewitness accounts of Young and Adayo placing appellant with the victim at the critical time, the discovery of the body, and the bloodstains in their home—formed an unbroken chain leading to the reasonable conclusion that appellant was the perpetrator. The defense of denial and alibi could not prevail over the positive circumstantial evidence.
However, the Court reduced the penalty from death to reclusion perpetua. The aggravating circumstances of nighttime and abuse of superior strength were not alleged in the information. Applying retroactively the favorable rule under Section 8, Rule 110 of the 2000 Revised Rules on Criminal Procedure, which requires such allegations, these circumstances could not be appreciated. With no aggravating or mitigating circumstances, the proper penalty under Article 63 of the Revised Penal Code is the lesser penalty of reclusion perpetua. Civil indemnity was accordingly set at Fifty Thousand Pesos (P50,000).