GR 132512; (December, 1999) (Digest)
G.R. No. 132512 December 15, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LYNDON SAÑEZ Y LACSON, accused-appellant.
FACTS
Lyndon Sañez was charged with parricide for the killing of his father, Raulito Sañez, on October 29, 1995, in Imus, Cavite. The prosecution presented circumstantial evidence and a dying declaration. Alberto Sañez, the victim’s brother, testified that upon finding Raulito wounded in a canal, the victim identified Lyndon as his assailant before expiring en route to the hospital. Eyewitness Cary Bataclan testified that he saw Lyndon dragging a body across the road and dumping it into a canal before cleaning the path. The police investigation revealed bloodstains and human tissue leading from the family washroom to the canal.
The defense presented an alibi, with Lyndon claiming he was asleep and later told his father was a vehicular accident victim. He suggested his uncle implicated him due to a property dispute and that the eyewitness was paid. The trial court convicted Lyndon of parricide and imposed the death penalty, prompting an automatic review by the Supreme Court.
ISSUE
Whether the guilt of the accused-appellant for the crime of parricide was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction but modified the penalty. The Court held that the combination of circumstantial evidence satisfied the requisites for conviction: there was more than one circumstance; the facts were proven; and their combination produced moral certainty of guilt. The dying declaration, made by the victim to his brother identifying his son as the assailant, was admissible as an exception to the hearsay rule, given the victim’s consciousness of impending death. The eyewitness account of the body being dragged and the forensic evidence tracing blood from the house to the canal corroborated the declaration.
However, the Court found the imposition of the death penalty erroneous. The information alleged treachery, but as there was no eyewitness to the actual attack detailing its execution, this aggravating circumstance could not be proven. For parricide under Article 246 of the Revised Penal Code, the penalty is reclusion perpetua to death. With no mitigating or aggravating circumstances attending the crime, the lesser penalty of reclusion perpetua must be applied pursuant to Article 63. The Court also modified the decision to order the accused to pay the heirs of the victim P50,000.00 as civil indemnity ex delicto.