G.R. No. 175603 February 13, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. RENATO ESPAÑOL, Appellant.

FACTS

Appellant Renato Español was charged with parricide for killing his wife, Gloria Pascua Español, on February 2, 2000, in Dagupan City. The prosecution presented evidence that at about 2:00 a.m., Domingo Petilla heard two gunshots and then saw a yellow tricycle speed past him. The body of Gloria was later discovered on Pantal Road. Harold Villanueva, a boatman, also heard the shots and saw a speeding yellow tricycle with the name “Rina” driven by a man in dark clothes. Appellant arrived at the crime scene shortly after, shouting, “She is my wife… Who killed her?” and claimed she was held up. Villanueva noticed appellant wore clothes similar to the tricycle driver’s. Appellant used a yellow tricycle belonging to Federico Ferrer, which had “Rina” on it, to go to the scene; his brother-in-law Mateo Pascua noticed the tricycle’s seats and floor were wet. At the morgue, appellant refused to look at the body. Later, at the police station, appellant privately begged his sister-in-law Felicidad Ferrer for forgiveness and asked to be spared from imprisonment. During the wake, appellant avoided the coffin and, when confronted by a nephew, remained silent. Evidence of appellant’s illicit relationship with another woman, Eva Seragas, was also presented, which had caused marital conflict. The defense presented an alibi, with appellant claiming he had dropped off his wife to visit her sister and was elsewhere buying medication, and his children corroborating his presence at home. The Regional Trial Court convicted appellant of parricide and sentenced him to reclusion perpetua, which the Court of Appeals affirmed.

ISSUE

Whether appellant is guilty of the crime of parricide.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found that the circumstantial evidence presented by the prosecution constituted an unbroken chain leading to the conclusion that appellant was the perpetrator. The established circumstances were: (1) appellant admitted he was with his wife shortly before her death, driving her in a yellow tricycle; (2) the same tricycle was seen fleeing the crime scene at high speed right after the gunshots; (3) appellant’s clothing matched that of the fleeing driver; (4) the tricycle’s interior was wet, consistent with it being recently used; (5) appellant’s unusual behavior at the crime scene, morgue, and wake; (6) his plea for forgiveness from his sister-in-law; and (7) his motive arising from an extramarital affair. These circumstances, taken together, satisfied the required proof beyond reasonable doubt for a conviction based on circumstantial evidence. The penalty of reclusion perpetua was affirmed, along with the award of civil indemnity.