GR 140794; (October, 2001) (Digest)
G.R. No. 140794; October 16, 2001
PEOPLE OF THE PHILIPPINES, appellee, vs. RICARDO AGLIDAY Y TOLENTINO, appellant.
FACTS
The appellant, Ricardo Agliday, was charged with parricide for shooting and killing his 19-year-old son, Richard Agliday. The prosecution presented eyewitness accounts from the victim’s mother, Conchita Agliday, and brother, Rey Agliday. They testified that on the evening of February 25, 1999, after a quarrel between the appellant and his wife, the victim intervened. The appellant then got a shotgun and deliberately shot his son. The victim died from the gunshot wound. The defense presented a starkly different version, claiming the shooting was accidental. The appellant asserted he was cleaning his homemade shotgun when it accidentally discharged, hitting his son who was nearby. The trial court convicted the appellant of parricide, sentencing him to reclusion perpetua.
ISSUE
The core issue is whether the appellant is guilty of parricide or merely of reckless imprudence resulting in homicide. The defense hinges on the claim of accidental shooting, which would negate criminal intent.
RULING
The Supreme Court affirmed the conviction for parricide, rejecting the defense of accident and the alternative claim of reckless imprudence. The Court emphasized that reckless imprudence involves a voluntary act done without malice, characterized by an inexcusable lack of precaution. Malice is its antithesis; where malice is proven, recklessness is negated. The Court found the prosecution witnesses credible. Their testimonies, being straightforward and coming from the appellant’s own wife and son, were deemed reliable and established a deliberate act. The appellant’s external acts—getting the gun after an argument and shooting his intervening son—proved criminal intent. The defense of accidental discharge was inconsistent with this deliberate sequence of events. The Court cited jurisprudence stating that a deliberate intent to do an unlawful act is incompatible with a finding of reckless imprudence. Since the shooting was intentional and the victim was the appellant’s son, the elements of parricide under Article 246 of the Revised Penal Code were satisfied. The penalty of reclusion perpetua and the award of civil indemnity were upheld.