G.R. No. L-3918 - People vs. Juan Erra, defendant-appellant

In June 1929, Eladio Castaneda and his wife Maria Fontillas were living together with their son Severino Castaneda in their house in the barrio of Siminublan, San Narciso, Zambales.
Another son of the couple, Felixberto (also known as Felixberto Fontillas alias Castaneda), was residing in a nearby separate house.

One night, while intoxicated, Eladio Castaneda was overheard scolding and threatening his wife, which prompted Maria Fontillas to call out for help as she fled the scene and sought refuge in the house of Felixberto.
Eladio, without any weapon in his hand, pursued his wife.
As the family members were fleeing, Severino Castaneda came out of their house and picked up a piece of chopped wood (approximately two feet long and three inches in diameter).

Upon reaching the kitchen, defendant Felixberto met Eladio and delivered a fist blow to the deceased’s left eye, which rendered him slightly groggy and caused him to tilt his head to the right.
At the same moment, Severino Castaneda struck Eladio with the piece of wood on the left temporal-parietal region of his head.
The blow resulted in a skull fracture and subsequent cerebral hemorrhage, leading to the death of Eladio a few hours later, the following morning.

After committing the act, Severino threatened to kill anyone who disclosed the details of the incident, causing witnesses to remain silent for four years out of fear.
Eventually, due to the efforts of the Constabulary, led by Lieuts. Canuto and Arambulo, the burial site of the deceased was located, his remains exhumed, and forensic evidence (notably, the intact coffin and perforated skull) was gathered.
An information charging Severino Castaneda and his brother Felixberto with the crime of parricide was filed before the justice of the peace in San Narciso on September 25, 1933.

The information clearly delineates that there was no conspiracy between the defendants since each executed separate, independent acts against their father.
Although Felixberto struck him on the left eye, the prosecution failed to establish that this act contributed to the death, whereas Severino’s blow with the wood was directly linked, as confirmed by medical evidence.

Severino Castaneda was arraigned in open court and, upon fully understanding the charges in his native dialect, voluntarily pleaded guilty to killing his father.
Despite the plea, the trial court required the prosecution to present its evidence to determine the appropriate penalty.
The defense sought to reproduce evidence from a previous trial against Felixberto, a request to which the prosecution did not object.

Severino admitted the killing but claimed the following mitigating circumstances:

The court, however, found his plea of incomplete defense of his mother unmeritorious, especially after the testimony of disinterested eye-witnesses disproved his claim that his father was armed and attacking his mother.

Whether the independent acts of Felixberto and Severino, performed without a conspiracy, should result in separate liability for the crime of parricide.
The extent to which the act of striking the deceased’s left eye by Felixberto contributed to the death, given the medical evidence that unequivocally identified Severino’s blow as the direct cause.

Whether the plea of incomplete defense (or incomplete self-defense) raised by Severino—asserting that his actions were in defense of his mother—has merit under the circumstances.
The proper relevance and weight of mitigating circumstances such as:

Whether the court should apply the provisions of Article 69 of the Revised Penal Code or those under Article 63 in determining the penalty.
The legality of imposing reclusion perpetua versus death, in light of the mandatory nature of the penalties for parricide under Article 246 of the Revised Penal Code.