PEOPLE v. DOLORES LORENZO Y CORSINO

FACTS:

The case involves accused-appellant Dolores Lorenzo, a policewoman, who was charged with the crime of parricide for allegedly killing her husband on July 30, 1990. The prosecution's version of the incident was that the appellant confessed to killing her husband and surrendered a blood-stained bolo and a fan knife to the police. On the other hand, the defense presented a different version of events, claiming that the appellant found her husband and their neighbor arguing, and that it was the neighbor who killed the husband. The trial court found the testimonies of the prosecution witnesses credible and gave weight to the appellant's extrajudicial confession. The trial court rejected the defense's theory and found the appellant guilty of parricide. The appellant then appealed to the Supreme Court, questioning the credibility of the witnesses, alleging suppression of evidence by the prosecution, and claiming that her guilt was not proven beyond reasonable doubt.

An additional excerpt was provided: The appellant in this case seeks to overturn the decision of the Regional Trial Court (RTC) which found her guilty of the crime of murder. The victim of the crime was the appellant's husband, who was allegedly killed by Robert Santos. The appellant claimed that she was innocent and that the prosecution failed to present sufficient evidence to prove her guilt. She accused the prosecution of suppressing evidence and contested the trial court's assertion that her failure to correct an entry in the police blotter was evidence against her. The appellant argued that it was the police's duty to arrest and prosecute Robert Santos, and not her responsibility to file a criminal complaint against him. She also claimed that the trial court erred in holding against her the failure to file her counter-affidavit, stating that she was in detention and suffering from trauma.

ISSUES:

  1. Whether the appellant's failure to correct the entry in the police blotter against her can be held against her.

  2. Whether the appellant's failure to file a criminal complaint against Robert Santos can be held against her.

  3. Whether the appellant's failure to file her counter-affidavit can be held against her.

  4. Whether the trial court erred in its evaluation of the appellant's testimony and that of her witnesses.

  5. Is the testimony of a single credible and positive witness sufficient to convict?

  6. Is the presence of corroborative evidence necessary?

  7. Did the alleged suppression of evidence affect the case?

  8. Whether the circumstances presented are sufficient to prove the appellant's guilt beyond reasonable doubt.

  9. Whether the penalty of reclusion perpetua is appropriate in this case.

RULING:

  1. The court held that the appellant's failure to correct the entry in the police blotter against her cannot be held against her since there is no evidence showing that she heard the report or saw the entry.

  2. The court held that the appellant's failure to file a criminal complaint against Robert Santos cannot be held against her as it was the duty of the police to arrest and prosecute Santos.

  3. The court held that the appellant's failure to file her counter-affidavit cannot be held against her as it is in accordance with her constitutional right to remain silent.

  4. The court upheld the trial court's evaluation of the appellant's testimony and that of her witnesses, as the trial court is in a better position to decide the credibility of witnesses.

  5. Yes, the testimony of a single credible and positive witness is sufficient to convict, as long as it satisfies the court as to the guilt of the accused beyond reasonable doubt.

  6. The presence of corroborative evidence is not necessary if the confession of the accused itself is proven to be admissible and credible.

  7. The alleged suppression of evidence has no merit, as the testimony of the witness in question would only be corroborative and the witness was available to the defense.

  8. Yes, the circumstances presented are sufficient to prove the appellant's guilt beyond reasonable doubt. The unbroken chain of circumstances points to the appellant as the guilty person. The requirements of Section 4, Rule 133 of the Rules of Court on the sufficiency of circumstantial evidence to convict the appellant are present.

  9. Yes, the penalty of reclusion perpetua is appropriate in this case. Despite the penalty for parricide being reclusion perpetua to death, the mitigating circumstances of voluntary surrender are present. Thus, pursuant to Rule 3, Article 63 of the Revised Penal Code, the proper penalty to be imposed is reclusion perpetua.

PRINCIPLES:

  • Appellate courts generally do not disturb findings of credibility made by the trial court, unless certain facts of value have been plainly overlooked which might affect the result of the case.

  • The trial court has a better opportunity to observe and consider certain potent aids in understanding and weighing the testimony of witnesses, such as emphasis, gesture, and inflection of voice, which are not incorporated into the record.

  • An accused who had nothing to do with the crime would be against the natural order of events and human nature for a prosecution witness to falsely testify against the accused.

  • In evaluating the testimony of a witness, the absence of evidence as to an improper motive strongly tends to sustain the conclusion that none existed and that the testimony is worthy of full faith and credit.

  • The testimony of a single person, if credible and positive, can be sufficient evidence, even without corroboration. Corroboration is only required for extrajudicial confessions and the evidence of corpus delicti.

  • The value and credibility of evidence should be weighed, not numbered.

  • The confession of the accused may be considered as evidence, whether it is characterized as a confession or an admission.

  • Minor inconsistencies in testimony do not necessarily affect the credibility of witnesses.

  • The presumption that evidence willfully suppressed would be adverse if produced does not apply when the testimony of the witness not produced would only be corroborative or when the witness is available to the defense.

  • The testimony of the accused may not be credible if he fails to inform the police authorities and the fiscal during the investigation that it was not him but somebody else who committed the crime.

  • Circumstantial evidence is sufficient to convict the accused if the circumstances form an unbroken chain leading to one fair and reasonable conclusion that points to the guilt of the accused. This must comply with the requirements of Section 4, Rule 133 of the Rules of Court.

  • The penalty for parricide under Article 246 of the Revised Penal Code is reclusion perpetua to death. However, if mitigating circumstances are present, the proper penalty should be determined in accordance with Rule 3, Article 63 of the Revised Penal Code.