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PEOPLE v. JOSE BELMAR UMAPAS Y CRISOSTOMO

FACTS:

In the evening of November 30, 1998, appellant Jose Belmar Umapas y Crisostomo mauled his wife Gemma Gulang Umapas and set her ablaze using alcohol intended for a coleman or lantern. Gemma suffered contusions, lacerations, and thermal burns over 57% of her body. She was brought to the hospital but died on December 5, 1998 due to multiple organ failure secondary to the burns. The police were initially prevented from talking to Gemma at the hospital, but they were able to interview her the next day. Gemma identified appellant as her assailant and agreed to give a statement about the incident. Appellant was later charged with parricide. During the trial, appellant claimed that he was unaware of the commotion at their house on the night of the incident and was brought to the police station instead of being able to go to the hospital. He also alleged that Gemma pointed him as the perpetrator due to her suspicions of him womanizing. The prosecution presented witnesses who testified about the severity of Gemma's injuries and her identification of appellant as the assailant. The defense, on the other hand, presented the lone testimony of appellant.

The appellant, Jose Belmar Umapas, was charged with the crime of parricide for allegedly setting his wife, Gemma Umapas, on fire. Gemma later died due to the severity of her injuries. At the crime scene, Gemma's daughter told the investigating officer that her mother was set ablaze by the appellant. However, the officer failed to reduce the daughter's statement in writing.

The appellant denied the accusation and claimed he was out fishing with a friend during the incident. He accused his wife of pointing to him as her assailant out of revenge for his alleged womanizing. The defense intended to present another witness but eventually rested its case when no other witness was available.

The Regional Trial Court (RTC) found the appellant guilty of parricide and sentenced him to imprisonment for reclusion perpetua. The court also ordered the appellant to pay damages to the victim's heirs. The RTC rejected the defense of alibi and denial presented by the appellant.

The appellant appealed the RTC's decision to the Court of Appeals. The Court of Appeals denied the appeal and affirmed the RTC's decision with modification, ordering the appellant to pay exemplary damages in addition to the damages awarded by the trial court.

The appellant then appealed to the Supreme Court, raising two issues: (1) whether the dying statement of the victim should be admitted as evidence; and (2) whether the prosecution failed to prove the appellant's guilt beyond reasonable doubt.

The Supreme Court affirmed the appellant's conviction for parricide. The court held that all the elements of parricide were established, namely the death of the victim, the fact that the appellant killed the victim, and the spousal relationship between the appellant and the victim. The court also recognized the dying declaration as admissible evidence, as it met the requirements for such evidence to be admitted.

ISSUES:

  1. Whether the dying declaration of the deceased victim is admissible as evidence

  2. Whether the circumstantial evidence is sufficient to establish the guilt of the accused

  3. Whether the testimonies of SPO1 Belisario, Dr. Tamayo, and SPO1 Garcia, which contain hearsay statements made by third parties, are admissible as circumstantial evidence.

  4. Whether the defense of alibi is credible.

  5. Whether the testimonies of the prosecution witnesses, who are police officers, should be given credence.

  6. Whether the penalty of death is prohibited in this case.

  7. Whether the penalty of reclusion perpetua is the correct penalty to be imposed in the absence of aggravating or mitigating circumstances.

RULING:

  1. The dying declaration of the deceased victim is admissible as evidence. Four requisites must concur for a dying declaration to be admissible: (a) the declaration must concern the cause and surrounding circumstances of the declarant's death, (b) the declarant must be under the consciousness of an impending death, (c) the declarant must be competent as a witness, and (d) the declaration must be offered in a criminal case for homicide, murder, or parricide where the declarant is the victim. In this case, the requisites were met as the deceased identified the accused as the person who attacked her before her death.

  2. The circumstantial evidence is sufficient to establish the guilt of the accused. Direct evidence of the actual killing is not indispensable for conviction when circumstantial evidence can sufficiently establish the accused's guilt. The circumstantial evidence in this case, combined with the dying declaration of the deceased, creates an unbroken chain of circumstances that leads to the fair and reasonable conclusion that the accused is guilty.

  3. The testimonies of SPO1 Belisario, Dr. Tamayo, and SPO1 Garcia, which contain hearsay statements made by third parties, are admissible as circumstantial evidence. These statements may be admitted not necessarily to prove their truth, but to establish the fact that the statements were made. The truth or falsity of the statements is immaterial.

  4. The defense of alibi is not credible. Alibi is an inherently weak defense and must meet the requirements that the accused was somewhere else when the crime occurred and that it was physically impossible for the accused to be at the scene of the crime. Mere denial or claim of being somewhere else is not enough; clear and convincing evidence of physical impossibility is required.

  5. The testimonies of the prosecution witnesses, who are police officers, are given credence. When police officers have no motive to testify falsely against the accused, courts presume the regularity in the performance of their duties and give weight to their testimonies.

  6. The penalty of death is prohibited.

  7. The penalty of reclusion perpetua is the correct penalty to be imposed in the absence of aggravating or mitigating circumstances.

PRINCIPLES:

  • Dying declaration is an exception to the rule against hearsay if the declarant made it under the consciousness of an impending death that is the subject of inquiry. It is considered evidence of the highest order and entitled to utmost credence.

  • Four requisites must concur for a dying declaration to be admissible: (a) the declaration must concern the cause and surrounding circumstances of the declarant's death, (b) the declarant must be under the consciousness of an impending death, (c) the declarant must be competent as a witness, and (d) the declaration must be offered in a criminal case for homicide, murder, or parricide where the declarant is the victim.

  • Circumstantial evidence is sufficient for conviction if: (a) there is more than one circumstance, (b) the facts from which the inferences are derived have been proven, and (c) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt.

  • Hearsay evidence is evidence whose probative force depends on the competency and credibility of persons other than the witness who seeks to produce it. However, if the purpose of placing a statement on record is merely to establish the fact that the statement was made, the hearsay rule does not apply.

  • The defense of alibi is an inherently weak defense and must meet the requirements of time and place being physically impossible for the accused to be at the scene of the crime at the time of its commission.

  • The trial court's findings on the credibility of witnesses are given great weight on appeal, especially when affirmed by the Court of Appeals, as trial courts are in a better position to decide credibility, having heard the witnesses and observed their demeanor.

  • The penalty of death is prohibited.

  • In the absence of mitigating and aggravating circumstances, the lesser penalty shall be imposed.

  • Damages awarded to the heirs may be modified based on relevant jurisprudence.

  • Exemplary damages may be awarded for qualifying circumstances.

  • Damages awarded shall earn interest at the rate of six percent per annum from the date of finality of the judgment until fully paid.