In a parricide case, a wife’s dying declaration identifying her husband as her assailant can be powerful evidence leading to a conviction. This principle was affirmed in People v. Jose Belmar Umapas y Crisostomo, where the Supreme Court upheld the conviction based on the victim’s statement made while conscious of her impending death. This ruling emphasizes the weight given to such declarations in Philippine courts, especially when corroborated by circumstantial evidence, reinforcing the idea that final words can carry significant legal weight.

From Marriage Bed to Deathbed: Did a Wife’s Last Words Seal Her Husband’s Fate?

The case revolves around the tragic death of Gemma Gulang Umapas, who was allegedly mauled, doused with alcohol, and set ablaze by her husband, Jose Belmar Umapas. Gemma identified Jose as her assailant in a statement given to SPO1 Anthony Garcia while in the hospital, shortly before her death. The central legal question is whether Gemma’s statement, made under the belief of impending death, was admissible as a dying declaration and if it, along with other circumstantial evidence, was sufficient to convict Jose of parricide.

The Supreme Court, in affirming the lower courts’ decisions, emphasized the admissibility and weight of **dying declarations** under Philippine law. A dying declaration is an exception to the hearsay rule, admissible when the declarant is conscious of impending death and speaks about the cause and circumstances of their demise. The Court reiterated the four requisites for a dying declaration to be admissible:

First, the declaration must concern the cause and surrounding circumstances of the declarant’s death. Second, at the time the declaration was made, the declarant must be under the consciousness of an impending death. Third, the declarant is competent as a witness. Fourth, the declaration must be offered in a criminal case for homicide, murder, or parricide, in which the declarant is the victim.

The Court found that all four requisites were met in Gemma’s statement. Her identification of Jose as her attacker directly related to the cause and circumstances of her death. Considering the severity of her burns and injuries, it was reasonable to presume she believed death was imminent. There was no evidence suggesting Gemma was incompetent to testify had she survived. The statement was presented in a parricide case where Gemma was the victim. Building on this, the Court also considered the circumstances surrounding Gemma’s statement. The testimony of SPO1 Garcia, who recorded Gemma’s statement, and Dr. Tamayo, who treated her injuries, were crucial in establishing the context and admissibility of the declaration. The nurse’s presence as a witness further validated the statement’s authenticity.

Beyond the dying declaration, the Court also considered **circumstantial evidence** presented by the prosecution. This included the testimony of PO1 Belisario, who recounted that Gemma’s daughter identified Jose as the assailant immediately after the incident. Dr. Tamayo also testified that a certain Rodrigo Dacanay informed him that Jose was the one who set Gemma ablaze. While these statements were considered hearsay, the Court admitted them as **independently relevant statements**. The statements were not used to prove the truth of the matter asserted (that Jose committed the crime) but rather to establish that such statements were made, which is relevant to understanding the sequence of events and the initial identification of the suspect.

The Court emphasized that conviction can rest on circumstantial evidence 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. In this case, Gemma’s dying declaration, combined with the testimonies of the witnesses and the circumstances surrounding the incident, formed an unbroken chain leading to the conclusion that Jose was responsible for Gemma’s death.

Jose’s defense relied heavily on **alibi**, claiming he was fishing with a friend at the time of the incident. However, the Court found this defense to be weak and unconvincing. For alibi to be considered, the accused must prove that they were somewhere else when the crime occurred and that it was physically impossible for them to be at the crime scene. Jose failed to meet this standard, as he was in the same vicinity (Kalakhan) as his residence when the crime took place. The lack of corroborating evidence for his alibi further undermined its credibility. Jose also failed to provide any plausible reason to impute ill motive on the part of the police officers who testified against him, thus the Court upheld the presumption of regularity in the performance of their duties.

Regarding the penalty, the Court affirmed the imposition of reclusion perpetua, as the crime of parricide, under Article 246 of the Revised Penal Code, is punishable by reclusion perpetua to death. With the prohibition of the death penalty under Republic Act No. 9346, and in the absence of any aggravating or mitigating circumstances, the lesser penalty of reclusion perpetua was correctly imposed.

Finally, the Court modified the amounts of damages awarded to Gemma’s heirs, aligning them with current jurisprudence. The civil indemnity and moral damages were increased to P75,000.00 each, and exemplary damages of P75,000.00 were also awarded due to the spousal relationship, a qualifying circumstance in parricide. Temperate damages remained at P50,000.00. All damages were subjected to an interest rate of six percent (6%) per annum from the date of finality of the judgment until fully paid, as per prevailing legal standards.

FAQs

What is a dying declaration?	A dying declaration is a statement made by a person who believes they are about to die, concerning the cause and circumstances of their impending death. It is admissible as evidence in court, despite being hearsay, because of the belief that a person facing death would not lie.
What are the requirements for a dying declaration to be admissible in court?	The requirements are: the declaration must concern the cause and circumstances of the declarant’s death; the declarant must be under the consciousness of an impending death; the declarant must be competent as a witness; and the declaration must be offered in a criminal case for homicide, murder, or parricide, in which the declarant is the victim.
What is the significance of circumstantial evidence in this case?	Circumstantial evidence, such as testimonies about statements made by others identifying the assailant, was used to corroborate the dying declaration. While not direct proof, it helped to build a stronger case against the accused by establishing a consistent narrative of events.
What is the defense of alibi, and why did it fail in this case?	Alibi is a defense where the accused claims they were elsewhere when the crime occurred. It failed because the accused could not prove it was physically impossible for him to be at the crime scene, and his alibi was not sufficiently corroborated.
What is the penalty for parricide in the Philippines?	Parricide is punishable by reclusion perpetua to death under Article 246 of the Revised Penal Code. However, with the abolition of the death penalty, the maximum sentence is now reclusion perpetua.
Why were the damages awarded to the victim’s heirs modified by the Supreme Court?	The damages were modified to align them with current jurisprudence and to ensure fair compensation for the loss suffered by the victim’s heirs. This included increasing the amounts for civil indemnity, moral damages, and awarding exemplary damages.
What does it mean for a statement to be admitted as an ‘independently relevant statement’?	An independently relevant statement is admitted not to prove the truth of its contents, but to show that the statement was made. In this case, the statements helped to establish the sequence of events and the initial identification of the suspect.
How does the presumption of regularity apply to police officers in this case?	The presumption of regularity means that courts assume police officers performed their duties properly unless there is evidence to the contrary. This presumption was upheld because the accused did not present any evidence of ill motive on the part of the police officers.

The Umapas case underscores the critical role of dying declarations and circumstantial evidence in Philippine criminal law, particularly in parricide cases. It serves as a stark reminder of the weight given to a victim’s last words and the importance of a thorough investigation in securing justice.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, VS. JOSE BELMAR UMAPAS Y CRISOSTOMO, G.R. No. 215742, March 22, 2017