Philippine Supreme Court Resolutions

G.R. No. 191397 (People of the Philippines v. Jaime Garcia). - We resolve the appeal, filed by accused Jaime Garcia (appellant), from the August 26, 2009 decision of the Court of Appeals (CA) in CA-G.R. CR.-H.C. No. 03372.^[1]

The RTC Ruling

In its January 22, 2008 decision, the Regional Trial Court (RTC) of Antipolo City, Branch 73, convicted the appellant of parricide committed against his father, Angel Garcia, on April 18, 1990. It gave credence to the testimonies of prosecution eyewitnesses Gerardo Garcia and Jocelyn Cimagala, the appellant's younger brother and sister, respectively, which it found to be straightforward and consistent. The RTC rejected the appellant's insanity defense as the appellant failed to present any evidence on his mental condition at the time of the fatal stabbing incident. It sentenced the appellant to suffer the penalty of reclusion perpetua. It also ordered him to pay the amounts of P50,000.00 as civil indemnity and P50,000.00 as moral damages.^[2]

The CA Ruling

On intermediate appellate review, the CA affirmed the RTC's appreciation of the prosecution eyewitnesses' straightforward testimony pointing to the appellant as the killer of their father, and of the insufficient evidence adduced by the appellant to prove his insanity defense.^[3]

We now rule on the final review of the case.

Our Ruling

We deny the appeal, but modify the awarded indemnities. 

We find no reason to reverse the findings of the RTC, as affirmed by the CA. We are convinced that the eyewitness accounts of Gerardo Garcia and Jocelyn Cimagala amply established the case for the prosecution. No motive affecting their credibility was ever imputed against them. The lower courts correctly rejected the appellant's insanity defense. The appellant failed to present a clear and convincing evidence regarding his mental state immediately before and during the fatal stabbing incident.^[4] The appellant's evidence only showed that he suffered some impairment in his mental faculties, but such impairment was not so complete as to deprive him of his intelligence or consciousness of his acts. In fact, the appellant was aware that he killed his father. Thus, the appellant failed to overcome the presumption of sanity.

The penalty for parricide under Article 246 of the Revised Penal Code is reclusion perpetua to death. Since neither aggravating nor mitigating circumstances attended the commission of the felony, the lower courts properly imposed the penalty of reclusion perpetua on the appellant.

While we affirm the lower courts' factual findings and the imprisonment imposed, we find it necessary to modify the appellant's civil liability. We award temperate damages of P25,000.00, even if there is no receipt or competent proof to show the amount of actual damages incurred by the victim's family; it was reasonable to expect that they incurred expenses for the burial of the victim.^[5] In addition, exemplary damages of P30,000.00 should be awarded since the qualifying circumstance of relationship is present, the crime committed being parricide.^[6]cralaw

WHEREFORE, the August 26, 2009 decision of the Court of Appeals in CA-G.R. CR.-H.C. No. 03372 is hereby AFFIRMED with MODIFICATION. Appellant Jaime Garcia is found guilty beyond reasonable doubt of parricide, and is sentenced to suffer the penalty of reclusion perpetua. He is ordered to pay the heirs of the victim the amounts of P50,000.00 as civil indemnity, P50,000.00 as moral damages, P25,000.00 as temperate damages, and P30,000.00 as exemplary damages.

SO ORDERED.

Very truly yours,

(Sgd.) TERESITA AQUINO TUAZON
Deputy Division Clerk of Court

Endnotes:

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^[1] Penned by Associate Justice Sixto C. Marella, Jr., and concurred in by Associate Justices Jose L. Sabio, Jr. and Arcangelita M. Romilla-Lontok; rollo, pp. 2-15.

^[2] Docketed as Criminal Case No. 97-13999; CA rollo, pp. 10-12.

^[3] Supra note 1.

^[4] People v. Tibon, G.R. No. 188320, June 29, 2010, 622 SCRA 510, 519; and People v. Opuran, 469 Phil. 698, 711 (2004).

^[5] People v. Lucero, G.R. No. 179044, December 6, 2010, 636 SCRA 533, 543; and People v. Asis, G.R. No. 177573, July 7, 2010, 624 SCRA 509, 531.

^[6] People of the Philippines v. Jay Maglian y Reyes, G.R. No. 189834, March 30, 2011; People v. Dela Cruz, G.R. No. 187683, February 11, 2010, 612 SCRA 364, 374.