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Case 177: Can a son be convicted of parricide based solely on the testimony of a single eyewitness, despite the absence of corroborating physical evidence and motive?

327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination

Can a son be convicted of parricide based solely on the testimony of a single eyewitness, despite the absence of corroborating physical evidence and motive?

Case Title:

People of the Philippines vs. Paulino Delos Santos Jr. alias "Skylab"

G.R. No. 248929, November 09, 2020

Facts of the Case:

Paulino Delos Santos Jr., alias "Skylab," was accused of parricide for the death of his father, Paulino Delos Santos Sr. The incident occurred on May 8, 2011, at around 11:30 PM in Purok 2, Barangay Macolabo Island, Paracale, Camarines Norte. On the night of the incident, Paulino Jr. allegedly arrived intoxicated at a family gathering and engaged in a verbal altercation with his brother, Marcos. Their father, Paulino Sr., intervened and asked Paulino Jr. to leave.

Ignoring his father's advice, Paulino Jr. reportedly challenged his father to a fight and, after a brief physical struggle, stabbed him in the chest with a bladed weapon, resulting in the latter's immediate death. The prosecution presented Michael L. San Gabriel as the key witness, who positively identified Paulino Jr. as the attacker. The defense, however, claimed that Paulino Jr. did not commit the crime and offered an alibi. He testified that he was near the scene but did not kill his father and that another family member was responsible for the crime.

In its decision dated September 5, 2016, the Regional Trial Court of Daet, Camarines Norte (Branch 39), convicted Paulino Jr. of parricide. The court sentenced him to reclusion perpetua without eligibility for parole and ordered him to pay civil indemnity, moral damages, and exemplary damages. Paulino Jr. appealed to the Court of Appeals, claiming the prosecution failed to prove his guilt beyond a reasonable doubt, particularly criticizing the lack of corroborating witnesses and his supposed lack of motive.

However, the Court of Appeals affirmed the trial court's decision on June 28, 2018, modifying the ruling by imposing legal interest on the damages awarded.

Issue Before the Supreme Court:

Did the Court of Appeals err in affirming Paulino Jr.'s conviction for parricide despite the alleged lack of corroborative evidence and motive?

Supreme Court's Ruling:

The Supreme Court affirmed the conviction of Paulino Delos Santos Jr. for parricide with modifications. The Court held that all elements of parricide were present: a person was killed, the accused was identified as the killer, and the victim was a direct family member of the accused. The Court upheld the credibility of the sole eyewitness, Michael L. San Gabriel, whose testimony was deemed straightforward and consistent.

The Court ruled that the lack of a motive or corroborating witnesses did not undermine the positive identification of the accused as the perpetrator. Citing jurisprudence, it reiterated that motive is not essential in crimes where the identity of the offender has been clearly established. The Court also disregarded the defense of alibi, noting that the appellant was near the crime scene and could have easily committed the offense.

The Supreme Court adjusted the amounts of moral and exemplary damages to P75,000 each, in line with prevailing jurisprudence, and added P50,000 as temperate damages. These amounts were subject to 6% interest per annum from the finality of the decision until fully paid.

Dispositive Portion:

"WHEREFORE, the appeal is DISMISSED. The Decision dated June 28, 2018, of the Court of Appeals in CA-G.R. CR-HC No. 08894 is AFFIRMED with MODIFICATION. Appellant Paulino Delos Santos Jr. is found GUILTY of parricide and sentenced to reclusion perpetua. He is required to pay civil indemnity, moral damages, and exemplary damages of P75,000.00 each; and temperate damages of P50,000.00 to the heirs of Paulino Delos Santos Sr. These amounts shall earn six percent (6%) interest per annum from finality of this Decision until fully paid."

Should a single witness's testimony be sufficient for a conviction, even in cases where there is no physical evidence or apparent motive?

Important Doctrines:

Positive Identification Trumps Alibi:
The Court held that a positive identification from a credible witness outweighs an accused's alibi, especially when the alibi is weak or unsubstantiated.

Motive is Not Necessary When the Perpetrator is Clearly Identified:
Even without a clear motive, a conviction can be sustained if the accused is positively identified as the perpetrator. The lack of motive does not equate to innocence.

Flight is Evidence of Guilt:
The accused's act of fleeing the scene of the crime was considered an indication of guilt. An innocent person would ordinarily stay to clear his name.

Classification: Criminal Law (Parricide)

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🎓 Welcome, future lawyers and bar takers. In this content, we will examine the Supreme Court jurisprudence in People of the Philippines vs. Paulino Delos Santos Jr., G.R. No. 248929, promulgated on November 9, 2020. This case offers substantive insights on the crime of parricide and the standards of eyewitness credibility, motive, and evidentiary weight—crucial concepts in Criminal Law.

This material is intended to help law students and bar reviewees recall and understand the doctrines and legal standards enunciated in the decision. We aim to make legal doctrines accessible, factual, and practical for those preparing for exams or needing a quick refresher.

⚖️ CASE BACKGROUND:

Title: People of the Philippines vs. Paulino Delos Santos Jr. alias “Skylab”

Parties: The People of the Philippines (Plaintiff-Appellee) vs. Paulino Delos Santos Jr. (Accused-Appellant)

G.R. No.: 248929

Date: November 9, 2020

Nature: Criminal Law – Parricide

Summary:

The case involves the conviction of Paulino Delos Santos Jr., who was accused of stabbing his father during a heated, intoxicated dispute. Despite the lack of physical evidence or multiple eyewitnesses, he was convicted based on the positive and credible testimony of a single eyewitness. The RTC and CA affirmed his guilt. The Supreme Court upheld the conviction, emphasizing the sufficiency of credible sole eyewitness testimony, and reiterated key doctrines in evaluating criminal responsibility.

💬 Should one credible witness be enough to convict someone of parricide, or should courts demand corroborative physical evidence to protect against wrongful convictions?

Comment your insights below.

📚 TOP 10 IMPORTANT DOCTRINES

Positive Identification Overrules Alibi
➤ A credible and categorical identification by an eyewitness is more reliable than the accused's denial or alibi—even if uncorroborated.
[See: pp. 11–12, rollo]
Motive Is Not Required If Identity Is Established
➤ The prosecution is not required to prove motive when the identity of the accused as the perpetrator has been clearly established.
[See: p. 12, citing People v. Ducabo]
Flight Indicates Guilt
➤ An accused who flees the scene may be presumed guilty; innocent persons usually have no reason to flee.
[See: pp. 13–14, citing People v. Pentecostes]
Sole Witness Rule
➤ The testimony of a single witness, if credible, is sufficient to convict. Quantity of witnesses does not equate to truth.
[See: p. 12, citing People v. Hillado]
No Need for Birth Certificate in Parricide
➤ Oral or sworn admission of filiation during trial suffices to prove relationship in parricide.
[See: p. 12, citing People v. Ayuman]
Minor Inconsistencies Do Not Affect Credibility
➤ Variations in minor details (e.g., weapon specifics or direction of blow) do not weaken an eyewitness’s overall credibility.
[See: p. 12]
Weight of Evidence Over Number of Witnesses
➤ The Court reiterated that evidence is judged based on quality, not quantity.
[See: p. 12, citing People v. Hillado]
Trial Court’s Factual Findings Respected
➤ The SC gives great weight to trial court findings when supported by evidence and affirmed by the CA.
[See: p. 14]
Moral and Exemplary Damages Standards
➤ SC adjusted moral and exemplary damages to ₱75,000 each in accordance with current jurisprudence.
[See: final ruling portion]
Interest on Damages
➤ All damages awarded shall earn 6% interest per annum from finality of judgment until fully paid.
[See: dispositive portion]

❓ FREQUENTLY ASKED QUESTIONS (FAQs):

Q: Can one eyewitness convict someone of a crime?
A: Yes. As long as the testimony is credible, clear, and categorical.
Q: Is motive necessary in every criminal case?
A: No. When identity is clearly proven, motive becomes unnecessary.
Q: What if no physical evidence is found—can there still be conviction?
A: Yes, especially if eyewitness testimony is strong and credible.
Q: Why was Paulino Jr. still convicted despite denying the crime?
A: His alibi was weak, and his identification by a witness was strong and consistent.
Q: What is parricide under Philippine law?
A: It is the killing of one’s parent, child, spouse, or other close relative under Article 246 of the Revised Penal Code.

⚠️ DISCLAIMER:

This content is for educational purposes only and does not guarantee infallibility. It was created using premium Artificial Intelligence for legal awareness and review assistance.

📌 Case: People vs. Paulino Delos Santos Jr., G.R. No. 248929, November 9, 2020

📚 Classification: Criminal Law

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🎓 INTRODUCTION TO THE LAW QUIZZER

Welcome, law students and bar reviewees. This short quizzer focuses on a landmark criminal law case that reached the Supreme Court: People of the Philippines vs. Paulino Delos Santos Jr. alias “Skylab”, G.R. No. 248929, promulgated on November 9, 2020.

This case is classified under Criminal Law, specifically Parricide, and involves the tragic killing of a father by his own son during a heated, intoxicated confrontation. The central issue revolved around whether a single eyewitness's testimony—without corroborating evidence or clear motive—was enough to sustain a conviction.

The trial court convicted the accused, and this was affirmed by the Court of Appeals. The Supreme Court upheld the conviction, ruling that the positive and credible identification of the accused as the perpetrator was sufficient to prove guilt beyond reasonable doubt.

📌 The answer key will be provided at the end of the video, so get your notes ready and test your legal reasoning!

🔍 10 EASY-HOTS MULTIPLE CHOICE QUESTIONS (NO ANSWERS YET)

What was the main criminal charge against the accused in this case?
A. Murder
B. Homicide
C. Parricide
D. Frustrated Homicide
What was the relationship between the accused and the victim?
A. Friends
B. Father and son
C. Employer and employee
D. Brothers
What evidence primarily led to the conviction of the accused?
A. CCTV footage
B. Confession
C. Positive eyewitness identification
D. Forensic report
Which factor was considered unnecessary because the identity of the accused was clearly established?
A. Presence of the weapon
B. Medical certificate
C. Proof of motive
D. Testimony of a second witness
What did the courts say about the weight of a single eyewitness testimony?
A. It must always be corroborated
B. It can be enough if found credible
C. It is never sufficient
D. It must come from a relative
Which behavior of the accused was viewed as suggestive of guilt?
A. Hiring a lawyer immediately
B. Going to the police station
C. Fleeing the crime scene
D. Posting on social media
What was the nature of the confrontation before the killing occurred?
A. Political debate
B. Property dispute
C. Heated drunken argument
D. Inheritance discussion
How did the Court treat the accused's denial and alibi?
A. Given more weight than eyewitness account
B. Accepted as a valid defense
C. Treated as credible due to lack of motive
D. Dismissed as weak and self-serving
What was the final penalty imposed by the Supreme Court on the accused?
A. Death penalty
B. Life imprisonment without parole
C. Reclusion perpetua
D. Indeterminate sentence
What damages were awarded by the Supreme Court to the victim’s heirs?
A. No damages
B. Civil indemnity only
C. Nominal and moral damages
D. Civil, moral, exemplary, and temperate damages