G.R. No. 125518 July 20, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN REYES y GUTIERREZ, accused-appellant.

FACTS

Accused-appellant Benjamin Reyes was charged with parricide for stabbing to death his 13-year-old daughter, Cherry Reyes. The incident occurred on March 10, 1994, in San Juan, Batangas. Cherry had left their house after dinner to go to a neighbor’s house to watch television, with her mother’s permission but without informing her father. Upon learning of Cherry’s departure, Benjamin became furious and left the house with their nine-year-old son, Donnie. That evening, screams were heard. The following morning, Cherry’s body was found with multiple stab and incised wounds. The police investigation led to sworn statements from the mother, Julieta, and the eyewitness son, Donnie, implicating Benjamin. Donnie’s statement detailed that his father, using a fan knife (balisong), struck Cherry with a coconut midrib and then stabbed her multiple times near a neighbor’s house, after which Benjamin washed his hands in a river and threatened Donnie not to tell anyone. At trial, Julieta initially testified she witnessed the stabbing but later retracted, claiming she only learned of the killing the next morning and that Donnie was the actual eyewitness. Donnie maintained his testimony that his father was the killer. Benjamin denied the charge, claiming he was at home and only discovered his daughter’s body the next morning. The trial court found Benjamin guilty of parricide and sentenced him to death.

ISSUE

Whether the guilt of the accused-appellant has been established beyond reasonable doubt.

RULING

Yes, the guilt of the accused-appellant was established beyond reasonable doubt. The Supreme Court affirmed the conviction for parricide. The Court found the testimony of the eyewitness, Donnie, to be credible, straightforward, and consistent with his sworn statement. His account was corroborated by the physical evidence and the number of wounds inflicted, indicating a determined effort to kill. The Court held that the relationship between the accused and the victim, his daughter, was sufficiently established, satisfying an essential element of parricide. The defense of denial could not prevail over the positive identification by the eyewitness. However, the Supreme Court modified the penalty. The trial court imposed the death penalty without discussing its legal basis. The information did not allege, and the prosecution did not prove, any aggravating circumstance. No mitigating circumstance was found. Therefore, applying Article 63 of the Revised Penal Code, the lesser penalty of reclusion perpetua was imposed in the absence of any aggravating or mitigating circumstance. The decision was affirmed with the modification of the penalty to reclusion perpetua.