G.R. No. L-13219-20 - People vs. Cruz

The appellant, Remigio Cruz, was married to Natividad Concepcion in March 1953 and had a daughter born the following year.
The couple resided in Manila at the house of Natividad’s parents.
The marriage was marked by recurrent conflicts: in 1954 and again in 1955, Natividad separated from the appellant, citing his penchant for beating her up, although reconciliations followed.

In early June 1956, the appellant brought his wife and their sick daughter to his parents’ home in Sta. Rita, Pampanga.

The appellant appeared disheveled and complained of headaches, suggesting physical and mental distress.
He sought medical help for his daughter from a physician, Dr. Lising.

Upon returning with the doctor, he discovered that his wife and daughter had left for Cabanatuan City, inciting his anger.
In an outburst of rage, he first slashed a jar of sugar with a bolo, an act indicative of his explosive temper.

Following his wife and daughter to Cabanatuan City, the appellant attempted to convince Natividad to return to Manila, even enlisting the aid of her father.
Between June 9 and 11, while staying with Natividad’s parents, he performed his domestic duties in a calm manner—helping with chores, displaying politeness, and attending to his daughter.
At about 8 o’clock in the evening of June 11, when Natividad was sewing and the appellant was reading a magazine (Reader’s Digest), noises were heard by Natividad’s sisters (Lourdes and Anita) as banging and the sound of shattering chinaware.
Upon investigation:

Anita and Lourdes discovered the appellant and Natividad conversing by the kitchen door, with the appellant holding a bolo.
Suddenly, the appellant began hacking his wife with the bolo.

Anita and Lourdes fled, with Anita being chased and overtaken by the appellant, who struck her on the head, rendering her unconscious.
Daniel Cabunta, the husband’s relative and a policeman’s kin, intervened by trying to stop the appellant; the latter swung the bolo at him.

The appellant then attempted an escape toward the City Hall, but was intercepted by Policeman Pedro Villanueva after Daniel Cabunta’s shout for help.

The appellant’s violent outburst when he smashed a glass jar of sugar upon learning that his wife and child had departed for Cabanatuan City.
A few minutes before the fatal assault, additional acts of property destruction (smashing plates and glasses) were observed.

The appellant was previously diagnosed with schizophrenia, paranoid type, during a 1948 hospitalization in Honolulu and subsequent confinement in the National Mental Hospital at Mandaluyong, Rizal.
Despite his release in 1948 as “mentally improved,” no treatment was rendered post-release, and the explosive temper evidenced in his actions was used to argue against a claim of complete insanity.

Whether the appellant’s contention that the marriage certificate is the sole “best evidence” rule proof holds merit.
Whether the unobjected oral evidence presented to prove the fact of the marriage is sufficiently admissible.

Whether the factual circumstances (sudden and unexpected attack) justify the conviction for frustrated murder committed with treachery.
If the appellant’s actions during the assault on Anita Concepcion indeed insured the execution of the crime without exposing him to danger.

Whether the appellant was truly insane or deprived of reason and will at the time of the commission of the crimes.
Whether his past diagnoses and observed behaviors (explosive temper, property destruction) amount to a complete deprivation of intelligence necessary to invoke insanity as a mitigating circumstance.