G.R. No. 167502 ; October 31, 2006
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PABLO CUDAL, accused-appellant.

FACTS

In the early morning of January 1, 1998, accused-appellant Pablo Cudal arrived at his home in Mangatarem, Pangasinan, intoxicated from a drinking session. He woke his 79-year-old father, Crispin Cudal, to demand money to pay for liquor. The victim refused, stating he had no money and that appellant was already drunk, leading to a physical altercation. Camilo Cudal, a cousin who heard the commotion from nearby, rushed to the scene and found the victim sitting on his bed, bleeding from a forehead wound. When asked, the victim immediately identified appellant as the one who hit him with a stone. The victim was brought for treatment but died the next day from internal hemorrhage secondary to craniocerebral trauma.
Appellant was charged with parricide. He denied the accusation, claiming self-defense. He testified that it was his father who attacked him with a bolo, and that the victim’s injuries were accidental—sustained when the victim fell against a bedpost and later onto the bolo’s handle. The Regional Trial Court convicted appellant of parricide, sentencing him to reclusion perpetua, considering his intoxication as a mitigating circumstance. The Court of Appeals affirmed the conviction with modification to the civil indemnity. The case was elevated to the Supreme Court for final review.

ISSUE

Whether the conviction of Pablo Cudal for the crime of parricide is supported by evidence beyond reasonable doubt.

RULING

Yes, the conviction is affirmed. The Supreme Court upheld the findings of the lower courts, ruling that the prosecution successfully established appellant’s guilt. The Court gave credence to the testimony of Camilo Cudal, who recounted the victim’s spontaneous declaration identifying appellant as his assailant. This statement, made immediately after the startling incident while the victim was still bleeding, qualifies as part of the res gestae and is thus admissible as an exception to the hearsay rule. It carries a high degree of trustworthiness as it was uttered without opportunity for reflection or fabrication.
The Court found appellant’s claim of accidental injury unconvincing and inconsistent with the medical evidence. The nature and location of the victim’s wounds contradicted the theory of a mere accidental fall. The trial court’s assessment of witness credibility is accorded great weight, as it is in a better position to observe demeanor. The mitigating circumstance of voluntary intoxication was correctly appreciated, as there was no proof it was habitual or intentional, warranting the imposition of reclusion perpetua, the lesser penalty in the range prescribed for parricide. The appealed decision was affirmed in toto.