GR 215742; (March, 2017) (Digest)
G.R. No. 215742 March 22, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs JOSE BELMAR UMAPAS y CRISOSTOMO, Accused-Appellant
FACTS
On November 30, 1998, appellant Jose Belmar Umapas mauled his wife, Gemma, doused her with alcohol, and set her ablaze at their home in Olongapo City. Suffering from contusions, lacerations, and thermal burns over 57% of her body, Gemma was rushed to the hospital. The following day, while receiving treatment, SPO1 Anthony Garcia interviewed her. Though weak and speaking slowly, Gemma was coherent and identified her husband as her assailant. When asked if she felt she was dying, she answered “yes.” Her statement was reduced to writing and attested by her thumbmark. She succumbed to multiple organ failure on December 5, 1998.
At trial, the prosecution presented the medico-legal officer and the investigating officer. The defense consisted solely of appellant’s testimony, where he denied the accusation and presented an alibi, claiming he was out fishing at the time of the incident. He suggested his wife implicated him due to her suspicion of his infidelity. The Regional Trial Court convicted him of parricide, a decision affirmed with modification by the Court of Appeals.
ISSUE
The core issue is whether the dying declaration of the victim and the circumstantial evidence presented are sufficient to sustain appellant’s conviction for parricide beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court upheld the admissibility and reliability of Gemma’s dying declaration. For a statement to qualify as a dying declaration under Section 37, Rule 130 of the Rules of Court, the declarant must have been conscious of their impending death. This condition was satisfied when Gemma affirmatively answered that she felt she was dying, a perception supported by the attending physician’s testimony regarding the severity and fatal nature of her burns. Her identification of appellant as the perpetrator was thus admissible as an exception to the hearsay rule.
The Court found appellant’s denial and alibi inherently weak and unsubstantiated. He failed to present the alleged companion, Rommel, to corroborate his fishing alibi. In contrast, the prosecution evidence formed an unbroken chain of circumstantial evidence consistent only with the hypothesis of guilt. This included the dying declaration, the medical findings, and the testimony about the events leading to her hospitalization. The combination of these facts led to a moral certainty of appellant’s culpability. The Court modified the penalty to reclusion perpetua without eligibility for parole, in accordance with prevailing jurisprudence, and affirmed the awarded damages.