People v. Castillo, Jr.
REITERATIONFacts
The Antecedents: On November 6, 1993, Domingo Castillo, Jr. (appellant) and his father, Domingo Castillo, Sr. (victim), were drinking beer at D & G Restaurant. After drinking, they boarded a blue pick-up truck driven by the appellant. An argument ensued during the trip home regarding the appellant's desire to return to the restaurant. Upon nearing their house, the appellant stopped the truck. The victim alighted and stood in front of the truck, challenging the appellant to run him over. The appellant slowly drove the truck forward, threatening the victim, who exclaimed, "papatayin mo ba ako?" The appellant then backed up, nearly hitting an owner-type jeep, and subsequently drove the truck forward at high speed, hitting the victim. He then reversed the truck, running over the victim a second time. The appellant alighted and walked towards their house. Another witness observed the truck moving forward and backward multiple times before discovering the victim's body. The victim was rushed to the hospital where he expired. Procedural History: The appellant initially passed off the death as an accident. However, his sister, Leslie C. Padilla, upon arriving from the US, became suspicious and engaged the National Bureau of Investigation (NBI). The NBI investigation confirmed foul play, leading to the filing of an information for parricide. The Regional Trial Court (RTC) of Bulacan found the appellant guilty beyond reasonable doubt of parricide and sentenced him to reclusion perpetua and P250,000.00 in actual damages. The Petition: The appellant appealed the RTC decision, claiming the act was committed through reckless imprudence and not with intent to kill, asserting he accidentally stepped on the gas pedal. The sole issue before the Supreme Court was whether the parricide was committed through reckless imprudence.
Issue(s)
Whether the killing of the victim was committed through reckless imprudence or with intent to kill. Whether the award of actual damages was proper.
Ruling
The Supreme Court affirmed the judgment of conviction for parricide, sentencing the appellant to suffer the penalty of reclusion perpetua. The award of actual damages was deleted, and the appellant was ordered to pay the other heirs of the victim P50,000.00 as moral damages.
Ratio Decidendi
On the issue of reckless imprudence versus intent to kill: The Supreme Court held that the appellant's actions demonstrated a deliberate intent to kill, which is inconsistent with reckless imprudence. The Court emphasized that criminal negligence requires an unintentional injury resulting from an act done without malice but with lack of foresight, carelessness, or negligence. The testimony of prosecution witness Ma. Cecilia Mariano indicated that the appellant was "intimidating" the victim by moving the pick-up forward before hitting him, prompting the victim's exclamation. Furthermore, the appellant's act of backing up to gain momentum before accelerating at high speed, and then reversing again to run over the victim a second time, evinced a clear intent to cause death. The Court found the appellant's claim of accidental acceleration to be unworthy of credence, especially considering his subsequent actions. The normal reaction of a person who accidentally ran over another would be to immediately alight and render aid; however, the appellant instead reversed the vehicle, ensuring the victim's death. His failure to promptly summon help and his walking away from the scene, as testified by Arthur Agaran, further contradicted his claim of accident and pointed towards a cold-blooded killing. The Court reiterated the rule that evidence must be credible in itself and probable under the circumstances, and the appellant's testimony, revealing past differences and resentment towards his parents, further supported the conclusion that the act was not accidental. On the award of actual damages: The Supreme Court deleted the award of actual damages because none were proven in court. The Court found that while the appellant was liable for the death of his father, the pecuniary losses incurred by the heirs were not substantiated by evidence presented during the trial. Therefore, the award of P250,000.00 as actual damages by the RTC was set aside. However, the Court found it proper to award moral damages to the other heirs of the victim, recognizing the emotional suffering and grief caused by the parricide.
Main Doctrine
The deliberate intent to do an unlawful act is inconsistent with reckless imprudence. Criminal negligence requires an unintentional injury resulting from an act done without malice but with lack of foresight, carelessness, or negligence.