G.R. No. 184172 ; May 8, 2009
THE PEOPLE OF THE PHILIPPINES, Appellee, vs. LUIS ANTONIO GARCHITORENA, Appellant.

FACTS

The appellant, Luis Antonio Garchitorena, was charged with the parricide of his wife, Flordeliza Tabla Garchitorena, on August 16, 2000, in Quezon City. The prosecution presented evidence that the spouses were alone in their bedroom when a gunshot was heard. The police investigator found the victim dead from a gunshot wound to the right side of her head, with a downward trajectory. A paraffin test on the victim was negative for gunpowder nitrates. The victim’s mother testified that her daughter had expressed fear of the appellant days before her death. The appellant claimed the death was a suicide, alleging that during an argument, he cocked his gun, and the victim grabbed it and shot herself.

ISSUE

Whether the prosecution proved the guilt of the appellant for the crime of parricide beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The prosecution successfully established the elements of parricide: the victim was killed; the appellant was the perpetrator; and the victim was his lawful spouse. The Court upheld the lower courts’ reliance on circumstantial evidence, which formed an unbroken chain leading to the reasonable conclusion that the appellant was guilty. This evidence included: the spouses being the only persons present; their prior altercation; the appellant’s retrieval of the gun; the medico-legal finding of a downward bullet trajectory inconsistent with a self-inflicted wound for a person alleged to be left-handed shooting her right temple; and the negative paraffin test on the victim. The appellant’s defense of suicide was rejected due to substantial inconsistencies between his statement to the police and his court testimony, and because his narrative was deemed contrary to human experience. The trial court’s assessment of witness credibility was accorded great weight, as no significant fact was overlooked that would alter the verdict.