People v. Brusola
REITERATIONFacts
The Antecedents: On July 12, 2006, at around 6:45 p.m., in Muntinlupa City, Abenir Brusola (Abenir) allegedly hit his wife, Delia Brusola (Delia), on the head with a maso (mallet). Their daughter, Joanne, testified that she saw her father strike her mother. Delia was rushed to the hospital but later died. Abenir was charged with parricide. Procedural History: The Regional Trial Court (RTC), Branch 206, Muntinlupa City, found Abenir guilty beyond reasonable doubt of parricide under Article 246 of the Revised Penal Code, sentencing him to reclusion perpetua and ordering him to pay ₱50,000.00 as indemnity and ₱50,000.00 as moral damages to the children of the deceased. The Court of Appeals (CA) affirmed the RTC decision. Abenir appealed to the Supreme Court. The Petition: Abenir appealed his conviction, arguing inconsistencies in prosecution witnesses' testimonies, alleged ill motive of the eyewitness (his daughter Joanne), and the trial court's failure to consider mitigating circumstances of passion, obfuscation, and voluntary surrender in imposing the penalty.
Issue(s)
Whether the guilt of the accused-appellant for parricide was proven beyond reasonable doubt. Whether the penalty of reclusion perpetua was correctly imposed, considering the alleged mitigating circumstances. Whether the awards for civil indemnity and moral damages are proper.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, finding Abenir Brusola guilty beyond reasonable doubt of parricide. The penalty of reclusion perpetua was upheld, and the awards for civil indemnity and moral damages were modified and increased. The Court also added exemplary damages.
Ratio Decidendi
On the guilt of the accused-appellant for parricide: The Court found that the prosecution sufficiently proved all the elements of parricide. The daughter Joanne's testimony, describing how she saw her father hit her mother with a maso on the head, was considered direct, positive, and credible evidence. The Court reiterated the rule that it is unnatural for a child to accuse someone else if not the real culprit, especially when there is nothing to indicate improper motives. The testimonies of Abigail and Kristofer, who saw Abenir holding the weapon and their mother with a bloodied head immediately after the incident, corroborated Joanne's account. The alleged inconsistencies in the testimonies of Joanne and Abigail were deemed minor details that did not affect their credibility, as they were consistent on the principal occurrence and the identity of the accused. The alleged ill motive of Joanne was also dismissed, as the loss of her mother and the potential loss of her father to prison outweighed any supposed disapproval of her early marriage. On the penalty of reclusion perpetua and mitigating circumstances: The Court clarified that the penalty for parricide, which is punishable by reclusion perpetua to death, is governed by Article 63 of the Revised Penal Code, as it involves indivisible penalties. Article 64, which deals with divisible penalties and allows for reduction by one degree, is not applicable. The Court affirmed that with the presence of the mitigating circumstance of voluntary surrender and no aggravating circumstances, the lesser penalty of reclusion perpetua was the proper imposition, as explained in People v. Sales. The Court distinguished this from People v. Genosa, where Article 64 was applied because the penalty for murder, unlike parricide, contains three periods. Therefore, the trial court's imposition of reclusion perpetua was correct. On the awards for damages: In line with current jurisprudence, the Court increased the civil indemnity and moral damages awarded to the victim's children to ₱75,000.00 each. Additionally, exemplary damages of ₱75,000.00 were awarded. The Court also mandated that all damages shall earn interest at the rate of six percent (6%) per annum from the date of finality of the judgment until fully paid.
Main Doctrine
The penalty for parricide, being punishable by two indivisible penalties (reclusion perpetua to death), is governed by Article 63 of the Revised Penal Code, not Article 64. Thus, the presence of a mitigating circumstance, such as voluntary surrender, with no aggravating circumstance, warrants the imposition of the lesser penalty of reclusion perpetua.