G.R. No. 248929, November 09, 2020
People of the Philippines, Plaintiff-Appellee, vs. Paulino Delos Santos, Jr. alias “Skylab,” Accused-Appellant.

FACTS

The accused-appellant, Paulino Delos Santos, Jr., was charged with parricide for the killing of his father, Paulino Delos Santos, Sr. The prosecution’s evidence, primarily through eyewitness Michael San Gabriel, established that on the evening of May 8, 2011, in Paracale, Camarines Norte, an intoxicated appellant arrived at a gathering and engaged in a heated argument with his brother. This awakened their father, who intervened. Appellant challenged his father to a fight, and during a physical confrontation, appellant stabbed his father in the chest, causing his instantaneous death. Appellant then fled the scene.
The defense presented a starkly different version. Appellant denied the killing, claiming he was awakened by noise, went outside, and saw his brother-in-law, Jovito Libanan, with bloodstained hands. He alleged he was prevented from entering Jovito’s house and was threatened. The Regional Trial Court found the prosecution’s version credible, convicted appellant of parricide, and sentenced him to reclusion perpetua without parole. The Court of Appeals affirmed the conviction but modified the damages and interest.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for parricide despite his defenses of denial and alibi and his claim that the prosecution failed to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction with modifications to the damages. The Court upheld the factual findings of the lower courts, emphasizing that the credibility assessment of the eyewitness by the trial court is accorded great weight. The positive and categorical testimony of Michael San Gabriel, who witnessed the stabbing and identified appellant as the perpetrator, was found clear and convincing. This direct evidence conclusively established all elements of parricide: that the victim was the appellant’s father, that he killed him, and that the killing was attended by treachery.
The Court rejected appellant’s defenses. Denial and alibi are inherently weak defenses and cannot prevail over the positive identification by a credible witness. The appellant’s claim of lack of motive was deemed irrelevant, as motive is not an element of the crime of parricide. The failure of other potential witnesses to testify did not create reasonable doubt, as the prosecution is not obligated to present every witness. The lone testimony of a credible eyewitness suffices for conviction if it meets the test of credibility, which it did here. The penalty of reclusion perpetua was affirmed, but pursuant to prevailing jurisprudence, the awards for civil indemnity, moral damages, and exemplary damages were increased to P75,000.00 each, with an additional P50,000.00 as temperate damages, all with legal interest.