G.R. No. L-2800 - People vs. Canja

The case involves the appellant Teopista Canja, who was charged and convicted of parricide for killing her husband, Pedro Jongque.
The case is recorded as 86 Phil. 518 [G.R. No. L-2800] and was decided on May 30, 1950.
The trial was conducted by the court of first instance of Antique, Philippines, where the incident occurred.

The couple resided in Barrio Badiangan, Patnongon, Antique, where family dynamics were disturbed by habitual vices.
Pedro Jongque was noted for squandering the family funds through gambling, maintaining a paramour, and developing a drinking habit that led to violent behavior.
The history of domestic strife included frequent quarrels and episodes of physical abuse, creating a climate of tension and fear.

The killing occurred on the night of May 25, 1948, at about 10 o’clock, within the conjugal home.

The family had retired to separate rooms, with the husband in one small room and the wife with the children in another.
An atmosphere of prior dispute is noted, as the couple had a discussion earlier that evening.

According to the testimony of Exuperia, the twenty-year-old eldest daughter, her mother insisted that the killing was necessary to prevent further violence from her husband.

Exuperia testified that her mother woke her up to report that her father was dead and that killing him was an act of self-preservation, albeit one that could cost her dearly.
Despite her misgivings, Exuperia assisted in removing the body to a nearby creek, indicating the premeditated and concealed nature of the act.

Reluta, accompanied by the sanitary inspector and justice of the peace, discovered the corpse in the creek on May 26, 1948.
He detailed the investigation procedure including the arrest of Teopista Canja and the preparation of Exhibit C containing her confession.

The post-mortem examination indicated that Pedro Jongque died from internal hemorrhage, and sustained multiple blunt force and incised wounds.
Injuries included fractures of facial bones, smashed dental arches, and a series of eleven incised wounds—findings inconsistent with a minimal self-defense response.

Exhibit C, forming part of the evidence, contained Teopista’s detailed confession which she signed voluntarily.
Benjamin Valente, the justice of the peace, corroborated that the confession was obtained in a controlled environment (police officers excluded), confirming its voluntariness.
The confession recounts an incident starting at about six o’clock in the evening on May 25, 1948, where a series of violent interactions culminated in Teopista using a hammer and chisel to kill her husband.

She claimed that she awoke to find a man strangling her and that, in self-defense, she struck him with a piece of wood.
According to her later statements, this led to the discovery that she had killed her husband.

The quantity and nature of the wounds (eleven incised wounds versus a couple of alleged strikes with wood) refuted the possibility of a mere self-defense scenario.
Her failure to mention the piece of wood to the police and the earlier plea of guilt during preliminary investigation further undermined her version.
Testimony from her daughter, who was expected to corroborate a self-defense claim if it were true, instead showed resentment and contradiction with her mother’s claim.

Whether Teopista Canja’s confession, given voluntarily and corroborated by judicial and police procedures, can be accepted as a true account of events.
The issue of whether her subsequent explanations or variations can override the written confession and witness testimonies.

Whether the evidence supports her claim of self-defense, given the nature and extent of the injuries inflicted upon her husband.
Evaluating if the history of abuse and provocation (husband’s vices and violence) could legally justify her actions under the doctrine of self-defense or a mitigating circumstance.

Considering the evidence and testimonies, whether the penalty (life imprisonment plus indemnity and costs) is in strict accordance with the provisions of the law (Article 246, Revised Penal Code).
Whether any mitigating factors, such as a history of abuse, should have led to a different judicial approach, including potential executive clemency.