People v. Sto. Tomas
REITERATIONFacts
The Antecedents: On May 23, 1967, at around 10:00 PM, Pacito Sto. Tomas arrived at the residence of the Grullas in Donsol, Sorsogon. After an argument with his wife, Salvacion Grulla, and her mother, Consolacion Grulla, regarding Salvacion's departure with him and their children, Pacito Sto. Tomas shot and killed Salvacion and Consolacion. He also shot Natividad Grulla, Salvacion's sister, who sustained near-fatal gunshot wounds. Procedural History: Three criminal cases were filed against Pacito Sto. Tomas: parricide for the death of Salvacion, murder for the death of Consolacion, and frustrated murder for the injuries sustained by Natividad. The trial court convicted the accused in all three cases and imposed penalties and damages. The accused appealed the decision. The Petition: The accused appealed his conviction, raising several assignments of error concerning the trial court's findings on the identity of Salvacion as his wife, the credibility of Natividad's testimony, the presence of treachery and abuse of superior strength, the consideration of dwelling as an aggravating circumstance, the finding of permanent deformity, the award of damages, and the conviction based on circumstantial evidence.
Issue(s)
Whether the accused-appellant's marriage to Salvacion Grulla was valid for the charge of parricide. Whether treachery attended the shooting of Natividad Grulla. Whether the aggravating circumstance of abuse of superior strength attended the commission of the offense. Whether the aggravating circumstance of dwelling was correctly considered. Whether Natividad Grulla suffered permanent deformity. Whether the conviction was based on sufficient circumstantial evidence. Whether evident premeditation attended the murder of Consolacion Grulla.
Ruling
The Supreme Court affirmed the judgment of the trial court with modifications to the penalties and damages awarded. The conviction for parricide, murder, and frustrated murder was upheld. The Court modified the penalties and increased the indemnities awarded to the heirs of the deceased and to Natividad Grulla.
Ratio Decidendi
On the validity of the marriage for parricide: The Court affirmed the trial court's rejection of the xerox copy of the alleged prior marriage certificate presented by the defense, citing the best evidence rule. The uncorroborated testimony of Prima Patanao was insufficient to overthrow the legality of the marriage between the appellant and Salvacion Grulla. Therefore, the conviction for parricide stands. On treachery in the shooting of Natividad Grulla: The Court found that treachery clearly attended the attack on Natividad. She was fired upon while entering her bedroom with her back turned to the appellant and while running away with her arms raised in surrender. This mode of attack ensured the execution of the crime without risk to the offender arising from any defense the victim might have made. On abuse of superior strength: The Court did not explicitly rule on this assignment of error in the dispositive portion, but the affirmation of the conviction implies that the trial court's finding on this matter was sustained or deemed not to have prejudiced the appellant's rights. On the aggravating circumstance of dwelling: The Court found no merit in the appellant's submission that dwelling should not be considered an aggravating circumstance. It reiterated that dwelling is aggravating when the crime is committed in the house of the victim, even if it was a temporary residence, citing previous jurisprudence. The crimes were committed in the house of Consolacion Grulla, where Salvacion was temporarily staying. On permanent deformity: The Court affirmed the finding that Natividad Grulla suffered permanent deformity. Her left arm became shorter than her right arm due to the gunshot wound, a condition beyond medical repair. This resulted in public ridicule and the loss of a scholarship grant. On conviction based on circumstantial evidence: The Court found that the evidence, particularly the multiple gunshot wounds on the deceased and the testimony of Natividad Grulla, was sufficient to establish the guilt of the appellant beyond reasonable doubt, even if direct evidence was lacking. The reloading of the gun after the alleged accidental firing further belied the appellant's theory. On evident premeditation in the murder of Consolacion Grulla: The Court found no evidence on record proving the existence of evident premeditation in the murder of Consolacion Grulla. It concluded that the appellant may only be liable for homicide for her death, as the shooting occurred during an argument, and the qualifying circumstance of evident premeditation was not established.
Main Doctrine
The Court affirmed the conviction for parricide, murder, and frustrated murder, modifying the penalties and damages. It held that the multiple gunshot wounds sustained by the victims conclusively negated the theory of accidental shooting, and that treachery attended the attack on Natividad Grulla. The Court also upheld the aggravating circumstance of dwelling and rejected the defense's attempt to invalidate the marriage through inadmissible xerox copies.