G.R. No. 139339 January 19, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL CASTILLO y GOMEZ, accused-appellant.

FACTS

Accused-appellant Manuel Castillo was charged with parricide for the death of his mother, Rosenda Castillo. The prosecution’s case rested primarily on the testimony of his niece, Maria Theresa Castillo, who lived with them. She testified that on the evening of November 16, 1994, an intoxicated Manuel assaulted Rosenda, who was an invalid, by kicking her multiple times and causing her to hit a piece of wood. This occurred as Rosenda was groping for a urine pan. Theresa witnessed the attack and stated that Manuel only stopped when she cried and rushed to help her grandmother, who was seriously injured and later died. The medico-legal officer confirmed the victim sustained severe injuries, including multiple fractures and brain hemorrhage, inconsistent with a mere fall.
The defense presented a different narrative, claiming Rosenda died a natural death in her sleep. Manuel, his common-law wife, and his son Rodel testified that nothing unusual happened that night, and they discovered Rosenda dead the next morning. They suggested the accusation was fabricated due to a family feud, implicating Manuel’s legal wife, Fe Regalado, who allegedly coerced Theresa into giving a false statement. The defense also presented affidavits of desistance from Theresa and another sister, which were later repudiated in court.

ISSUE

Whether the guilt of accused-appellant Manuel Castillo for the crime of parricide was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of prosecution witness Maria Theresa Castillo to be credible, straightforward, and consistent. Her detailed account of the violent incident was corroborated by the medico-legal findings, which established that the victim’s fatal injuries were caused by multiple blunt force trauma, not a simple fall. The Court emphasized that the trial court’s assessment of witness credibility is accorded great weight and respect. The affidavits of desistance presented by the defense were properly disregarded, as the witnesses subsequently repudiated them in open court, affirming their original testimonies. The defense of denial and alibi could not prevail over the positive identification and the physical evidence. The claim of improper motive by the legal wife was deemed insufficient to discredit the consistent prosecution evidence. The crime of parricide was thus established beyond reasonable doubt. The penalty of reclusion perpetua was affirmed, and accused-appellant was ordered to pay civil indemnity of P50,000 to the victim’s heirs.