GR 27791; (December, 1970) (Digest)
G.R. No. L-27791 December 24, 1970
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SANTIAGO MANOS, defendant-appellant.
FACTS
The defendant-appellant, Santiago Manos, was prosecuted and convicted of parricide for killing his father, Ricardo Manos. The prosecution’s eyewitness, Dionisia Malasarte, testified that on September 1, 1960, at about 6:00 PM, the deceased and the appellant were at her store. After a conversation where the deceased suggested going home, the appellant pushed his father, who fell face upward, and then fatally struck him with a bolo in the stomach and breast. Malasarte intervened and shouted for help. The appellant pleaded self-defense, claiming his father, who was drunk and displeased at his resignation from a brotherhood, rushed at him with a bolo. The appellant testified he tried to pacify his father and only held his bolo defensively, and the fatal wounds were inflicted when his father rushed onto the blade. The trial court gave credence to the prosecution witness and rejected the claim of self-defense.
ISSUE
The primary issue is whether the claim of self-defense by the appellant is credible and sufficient to exculpate him from the crime of parricide.
RULING
The Supreme Court affirmed the conviction. The Court found the appellant’s claim of self-defense to be incredible and upheld the trial court’s discretion in giving full credence to the testimony of the eyewitness, Dionisia Malasarte. The Court cited the established principle that appellate courts will not disturb the trial court’s findings on the credibility of witnesses, as the trial court is in a better position to observe their demeanor. The Court also noted that the presence of one mitigating circumstance (voluntary surrender) was immaterial to the penalty, as parricide is punishable by two indivisible penalties (reclusion perpetua to death), and with one mitigating circumstance, the lower penalty of reclusion perpetua is imposed. The decision was affirmed with the modification that the appellant indemnify the heirs of the deceased (excluding himself) in the sum of P12,000.00.