View full case

PEOPLE v. NOEL T. SALES

FACTS:

Noel T. Sales (appellant) was convicted of parricide and slight physical injuries for beating his two sons, Noemar and Noel Jr. Noemar and Noel Jr. left their home without permission and were found by their mother in a nearby Barangay the next day. When they returned home, appellant confronted them and whipped them with a stick. He then tied their hands and feet to a coconut tree and continued to beat them with a thick piece of wood. Noemar and Noel Jr. sustained injuries to their head, cheek, and legs. Noemar eventually lost consciousness and appellant sought the help of a quack doctor, but Noemar's body was never examined by a doctor and was immediately buried. Appellant claims that he only scolded and warned his sons in the past but on this occasion, he was angry with them for stealing a pedicab and hit them with a piece of wood as punishment.

According to the prosecution's evidence, appellant whipped his sons on their buttocks three times. Noemar began frothing and lost consciousness afterwards. Appellant attempted to bring Noemar to a hospital but they waited in vain for a vehicle at the crossroad. Noemar died during the wait and appellant decided to bring him back home. Appellant denies that his son died from the beating, claiming instead that Noemar died due to difficulty in breathing and a weak heart. The defense presented testimony from Noemar's mother, Maria, who stated that Noemar suffered from epilepsy and would have seizures when hungry or scolded. The death of Noemar was reported to the police by the barangay captain, leading to appellant's surrender. The trial court found appellant guilty and the appellate court affirmed the ruling. Appellant now appeals to the Supreme Court, arguing for acquittal and for the defense witnesses to be given more weight.

ISSUES:

  1. Whether the appellant committed the crime of parricide.

  2. Whether the appellant's claim of disciplining his son is a valid defense.

  3. Whether all the elements of parricide are present in this case.

  4. Whether the mitigating circumstance of lack of intention to commit so grave a wrong was properly appreciated.

  5. Whether the awards for damages and penalty for parricide were correctly imposed.

  6. Whether the appellant is guilty of the crime of slight physical injuries.

  7. Whether the penalty imposed by the Regional Trial Court (RTC) is correct.

RULING:

  1. The court found no error in the ruling of the trial court that the appellant committed the crime of parricide. The elements of parricide, as stated under Article 246 of the Revised Penal Code, are present in this case. The appellant killed his son, Noemar, who is covered by the definition of the deceased under the law. Therefore, the appellant is guilty of parricide and should be sentenced to reclusion perpetua to death.

  2. The court rejected the appellant's claim of disciplining his son as a valid defense. While parental discipline is allowed, it must be exercised with restraint and caution, and within the parameters of the parental duty. In this case, the court found that the appellant's actions went beyond discipline and were motivated by anger and an evil intent to vent his anger. The injuries sustained by Noemar were excessive and went beyond what is necessary for discipline. Therefore, the defense of disciplining the son was not valid in this case.

  3. Yes. The presence of the second element, the appellant killing the deceased, was established by the positive testimonies of Maria and Junior. The filial relationship between the appellant and the deceased was also proven through oral evidence. Therefore, all the elements of parricide are present in this case.

  4. No. The mitigating circumstance of lack of intention to commit so grave a wrong was not properly appreciated. The appellant adopted means to ensure the success of the savage battering of his sons and the injuries inflicted were sufficient to cause immediate death. Thus, the mitigating circumstance cannot be appreciated.

  5. The trial court's award of civil indemnity and moral damages to the heirs of the deceased is proper. However, the award of exemplary damages should be increased in accordance with prevailing jurisprudence. As for the penalty, although the trial court erred in considering the mitigating circumstance of lack of intent to commit so grave a wrong, the penalty of reclusion perpetua is still correct due to the presence of the mitigating circumstance of voluntary surrender.

  6. The appellant is guilty of the crime of slight physical injuries. The testimony of Junior, supported by his mother Maria and medical examination, provides credible evidence that he was beaten by his father and sustained injuries.

  7. The penalty imposed by the RTC is correct. Based on the medical examination, Junior's injuries should heal in one week with medication. Therefore, the penalty under paragraph 1, Article 266 of the Revised Penal Code (RPC) for slight physical injuries is proper. The RTC correctly imposed the penalty of twenty (20) days of arresto menor in its medium period due to the absence of mitigating or aggravating circumstances.

PRINCIPLES:

  • The imposition of parental discipline on children should be with the view of correcting erroneous behavior and must be exercised with restraint and caution.

  • Parental discipline should not exceed the parameters of the parental duty to discipline minor children and should not be motivated by anger.

  • In the crime of parricide, it is essential that a felony is committed and that the wrongful act done to the aggrieved person is a direct consequence of the crime committed.

  • The elements of parricide, as stated under Article 246 of the Revised Penal Code, are the killing of a person, the accused killing the deceased, and the deceased being the father, mother, child, ascendant, descendant, or spouse of the accused.

  • The presence of all the elements of the crime must be proven beyond reasonable doubt.

  • Mitigating circumstances may be considered if they were proven to be present.

  • Lack of intention to commit so grave a wrong cannot be appreciated if the acts employed by the accused were sufficient to and actually caused the death of the victim.

  • Damages may be awarded to the heirs of the deceased in cases of parricide, including civil indemnity, moral damages, and exemplary damages.

  • The penalty for parricide is reclusion perpetua to death, but with mitigating circumstances and no aggravating circumstances, the lesser penalty of reclusion perpetua may be imposed.

  • The testimony of a witness, when categorical and positive, deserves credence.

  • Corroboration of testimony, such as through the testimony of other witnesses and medical examination, strengthens the evidence.

  • The penalty for slight physical injuries under the RPC is arresto menor when the injuries inflict incapacity for labor from one to nine days or require medical attendance during the same period.

  • In the absence of mitigating or aggravating circumstances, the penalty shall be in its medium period.

  • The award of exemplary damages and the imposition of interest on monetary awards may be modifed or imposed by the court.