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Draft Decision Paper

The Regional Trial Court acquitted Ricardo Dalisay of parricide for the alleged murder of his father, Pablo De Leon, due to insufficient evidence to prove guilt beyond a reasonable doubt. The prosecution's case relied heavily on circumstantial evidence and witness testimony, which the court found inconsistent and unreliable. The court emphasized the constitutional presumption of innocence and the requirement for moral certainty in criminal convictions, ultimately ruling in favor of the accused.
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0% found this document useful (0 votes)
5 views

Draft Decision Paper

The Regional Trial Court acquitted Ricardo Dalisay of parricide for the alleged murder of his father, Pablo De Leon, due to insufficient evidence to prove guilt beyond a reasonable doubt. The prosecution's case relied heavily on circumstantial evidence and witness testimony, which the court found inconsistent and unreliable. The court emphasized the constitutional presumption of innocence and the requirement for moral certainty in criminal convictions, ultimately ruling in favor of the accused.
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


National Capital Judicial Region
Branch 07, City of Manila

PEOPLE OF THE PHILIPPINES


Plaintiff,
-versus-
RICARDO DALISAY
Accused.

CRIMINAL CASE NO. 080900


FOR: PARRICIDE

x---------------------------------------------------------------x

DECISION

Submitted for the Court’s resolution for the charge of Parricide under
Article 246 of the Revised Penal Code against Ricardo Dalisay, accused of
killing his father, Pablo De Leon. The trial was conducted before a jury,
where deliberation hinged on whether the evidence presented established
guilt beyond reasonable doubt.

Article 246 of the Revised Penal Code defines parricide as follows:

Art. 246. Parricide. – Any person who shall kill his father, mother, or
child, whether legitimate or illegitimate, or any of his ascendants, or
descendants, or his spouse, shall be guilty of parricide and shall be punished
by the penalty of Reclusion Perpetua to death.

"Parricide is committed when: (1) a person is killed; (2) the deceased


is killed by the accused; (3) the deceased is the father, mother, or child,
whether legitimate or illegitimate, or a legitimate other ascendant or other
descendant, or the legitimate spouse of accused."1i

The case also engages the constitutional principle of presumption of


innocence under Article III, Section 14(2) of the Philippine Constitution 2,
which mandates that "in all criminal prosecutions, the accused shall be
presumed innocent until the contrary is proved."

Statement of Facts

On the night of August 16, 2022, Pablo De Leon was found dead in
his home with a stab wound to the chest. Witnesses alleged that his son,
Ricardo Dalisay, was seen fleeing the scene. A neighbor claimed to have
heard an argument and saw the accused leaving the house shortly afterward.
The murder weapon, a kitchen knife, was found nearby with fingerprints
alleged to match the accused.

The defense denied the allegations, presenting an alibi that the accused was
at a theater watching a movie during the incident. They also challenged the
reliability of the eyewitness and the fingerprint evidence.
1
People v. Castro, G.R. No. 172370, 567 SCRA 586, 606 (Oct. 6, 2008)
2
CONST., art. III, § 14(2)
Issues Presented

1. Werther Ricardo Dalisay killed his father, Pablo De Leon.


2. Whether the evidence proves guilt beyond a reasonable doubt.

Evidence Presented

For the Prosecution:

1. Testimony of Ellen Padua, a neighbor, claiming she saw the accused


fleeing the scene.
2. The autopsy report confirming the cause of death as a stab wound to
the chest.
3. The alleged murder weapon, found with fingerprints matching the
accused.
4. Testimony from a police officer stating the accused had a motive due
to prior altercations with the victim.

5. The accused could not corroborate his alibi as he could not recall the
title of the movie he was watching at the time of the incident.

For the Defense:

1. Alibi of the accused, corroborated by a friend, that he was watching a


movie at a nearby theater during the incident.
2. Expert testimony suggesting that the fingerprints on the knife could
have been left at a different time.
3. Evidence challenging the reliability of Ellen Padua’s testimony,
including poor lighting, poor eyesight, and a history of inaccurate
statements.

Arguments of the Parties

Prosecution:

The prosecution contended that the combination of eyewitness


testimony, physical evidence, and the accused’s alleged motive conclusively
proved his guilt.

Defense:

The defense argued that the evidence was purely circumstantial and
insufficient to meet the threshold of proof beyond reasonable doubt, citing
the accused’s credible alibi and the unreliable nature of the prosecution’s
key witnesses.

Findings of Fact:

The court finds the following:

1. The prosecution’s evidence, particularly the testimony of Ellen Padua,


was inconsistent and failed to provide a reliable basis for identifying
the accused as the perpetrator due to including poor lighting and poor
eyesight.
2. The presence of the accused’s fingerprints on the murder weapon
could not conclusively establish his involvement, given the reasonable
possibility that they were left earlier.
3. The accused’s alibi, corroborated by multiple witnesses, cast
significant doubt on his alleged presence at the scene of the crime.

Article 246 of the Revised Penal Code defines parricide as the killing
of a parent by a descendant. While the prosecution presented evidence to
link the accused to the crime, the Supreme Court has held in People v. Liban
(G.R. No. 219852, June 7, 2017) 3that conviction requires proof beyond
reasonable doubt. Any doubt must be resolved in favor of the accused.

The Supreme Court, in People v. Mateo (2004) 4, emphasized that the


prosecution must rely on the strength of its evidence, not the weakness of the
defense. In addition, in People v. Modesto, (1968) 5, the Court held that
circumstantial evidence must form an unbroken chain leading to a singular
conclusion of guilt. The evidence here failed to meet this standard.

The constitutional presumption of innocence is central to the judicial


process. As reiterated in People v. Delim 6, (July 19, 2002), any reasonable
doubt must result in acquittal.

The prosecution’s case rested on circumstantial evidence, which,


while suggestive, did not establish the guilt of the accused beyond
reasonable doubt. The defense effectively demonstrated alternative
possibilities that the prosecution failed to negate.

The principle articulated in People v. Rayos (G.R. No. 127755,


October 12, 2000)7 that "moral certainty, not mere suspicion" is required for
a conviction, is directly applicable. The evidence in this case fell short of the
requisite standard.

Disposition

WHEREFORE, in view of the foregoing, the court hereby acquits the


accused, Ricardo Dalisay, of the charge of parricide on the ground of
reasonable doubt.

The accused is ordered released from detention unless he is lawfully


held for another cause.

SO ORDERED.

City of Manila; December 19, 2024.

3
People v. Liban, G.R. No. 219852, 819 Phil. 599 (June 7, 2017)
4
People v. Mateo, G.R. No. 147678, 433 SCRA 640 (July 7, 2004)
5
People v. Modesto, 25 SCRA 36 (September 21, 1968)
6
People v. Delim, G.R. No. 146621, 383 SCRA 316 (July 19, 2002)
7
People v. Rayos, G.R. No. 127755, 396 SCRA 478 (October 12, 2000)
HON. JUDGE HYNA P. SANTOS
Presiding Judge

Copy Furnished:

 Office of the City Prosecutor, Manila


 Public Attorney's Office, Manila
 Bureau of Jail Management and Penology, Manila
 Ricardo Dalisay
i

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