GR 180496; (April, 2014) (Digest)
G.R. No. 180496 , April 2, 2014
People of the Philippines, Plaintiff-Appellee, vs. Roy San Gaspar, Accused-Appellant.
FACTS
On April 25, 1999, at around 11:30 p.m., Roy San Gaspar (appellant) was charged with Parricide for killing his legitimate wife, Imelda E. San Gaspar, in their home in Isulan, Sultan Kudarat. The prosecution presented eyewitnesses Joramel and Cherme Estimo, the victim’s children from a previous relationship, who testified that appellant, after a heated altercation with Imelda, went upstairs, retrieved a .12 gauge shotgun, loaded it, and shot Imelda in the head at close range in their presence. The autopsy report confirmed the cause of death as a close-range gunshot wound to the head. The defense, however, claimed the shooting was accidental. Appellant testified that upon arriving home and pushing the bedroom door open, he heard a gunshot and found Imelda already wounded, suggesting the door hit the shotgun causing it to discharge. He then immediately sought help to bring her to the hospital.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s conviction of the appellant for the crime of Parricide, thereby rejecting his defense of accident.
RULING
The Supreme Court denied the appeal and affirmed the appellant’s conviction for Parricide. The Court held that all elements of Parricide were present: (1) Imelda was killed; (2) she was killed by the appellant; and (3) she was the legitimate spouse of the appellant. The positive and categorical testimonies of the eyewitnesses, who had no ill motive to falsely testify, prevailed over the appellant’s denial and implausible claim of accident. The physical evidence, including the trajectory of the gunshot and the presence of gunpowder residue, contradicted the defense’s theory and indicated an intentional shooting. The Court found no reason to disturb the factual findings of the trial court, as affirmed by the Court of Appeals, which are accorded great weight and respect. The penalty of reclusion perpetua was affirmed. The Court modified the awarded damages, ordering the appellant to pay the heirs of the victim Php 75,000.00 as civil indemnity, Php 75,000.00 as moral damages, and Php 30,000.00 as exemplary damages, with 6% interest per annum on all monetary awards from the finality of the decision until fully paid.