G.R. No. 148710 - PEOPLE OF THE PHILIPPINES, VS. JAIME BAÑO ALIAS “JIMMY,”.DECISION - Supreme Court E-Library

Ruling

Accordingly, the trial court sentenced Jaime to suffer the penalty of reclusion perpetua and to indemnify the family of Virginia Baño in the amounts of P100,000 as civil indemnity for moral damages; P40,000 for actual expenses; and the costs of the proceedings. Hence, this petition ascribing to the trial court grave error in finding him guilty beyond reasonable doubt of the crime of parricide on the basis of circumstantial evidence. In support of his lone assigned error, Jaime avers that the prosecution failed to prove the requisites for circumstantial evidence to be sufficient basis for conviction. He claims that the inferences were drawn not from facts established by direct evidence, but from other inferences. Only the circumstance that he regularly drinks liquor was proved, and the rest are mere presumptions. The fact that Virginias death was caused by intracerebral hemorrhage does not in any way evince that he inflicted the fatal wound. Neither his failure to attend the wake and burial of his wife at Bilabila nor his attempted suicide could be considered as indicia of his guilt. Instead, the first circumstance should be accepted as a normal reaction to a threat directed at his person by his wifes family, while the second should be deemed as the normal deportment of a grieving husband who loved his wife dearly. Additionally, the fact that Virginia returned to their house from Alicias house on the eve of her death proves that he did not maltreat her. His wife would not have sought the refuge of their conjugal home if, indeed, her life was threatened there. And even granting that he beat up his wife, such would not lead to a logical conclusion that he killed her. For its part, the Office of the Solicitor General (OSG) agrees with the trial court that the guilt of Jaime Baño was established through circumstantial evidence. The circumstances that lead to Virginias death constitute an unbroken chain of events pointing to Jaime as the author of her death. It recommends, however, the reduction of the award for actual damages from P40,000 to P30,710, in line with settled jurisprudence that only expenses supported by receipts and which appear to have been actually incurred shall be allowed as actual damages. We affirm the conviction of appellant Jaime Baño for the crime of parricide. While there was no eyewitness to the killing of Virginia, the following pieces of circumstantial evidence have indubitably established that he was responsible for her brutal demise. Virginia would often go to her hometown to complain to her family about the beatings she had been receiving from Jaime whenever he was inebriated. Even Kagawad Raymund Marquez, a barangay official and a long-time resident of Bucay, confirmed the regularity of the beatings whenever Jaime was drunk. On the night of 14 December 1996, Virginia sought refuge in the house of her relative and tearfully related her quarrel with Jaime that night. Afterwards, she came back and reported that her hus