G.R. No. 205836 - Bureau of Customs Employees Association vs. Biazon

On 28 August 1996, at around 2:30 PM, Guillermo Florendo alias "Imong" and his wife Erlinda Ragudo Florendo were inside their house in Barangay Bulbulala, La Paz, Abra, engaged in an animated conversation.
Without any provocation, Guillermo suddenly hacked Erlinda repeatedly with a bolo on her head and other parts of her body. Erlinda exclaimed, "Imong is going to kill me!"
Appellant’s father, Agustin Florendo, who was resting at the time, witnessed the incident but fled the house out of fear. He sought help from neighbor Ernesto Anical who urged him to inform the barangay captain.
The barangay captain was absent; his wife contacted barangay tanod Felipe Adora for assistance. When Agustin returned at about 4:00 PM, Erlinda was already dead.

Appellant went to the barangay captain’s house holding a bloodied bolo; the tanod disarmed him, and police authorities later took him into custody.
Autopsy by Dr. Corazon Lalin Brioso revealed Erlinda sustained 16 wounds, 4 of which were fatal, causing instantaneous death by hypovolemic shock due to massive hemorrhage.
On 2 September 1996, Guillermo was committed at the Abra Provincial Jail; he exhibited signs of mental disturbance including inability to sleep, refusal to eat, and standing silently.
A psychiatric examination was requested; on 20 November 1996, he was admitted to Baguio General Hospital and Medical Center (BGHMC) and diagnosed with schizophrenic psychosis, paranoid type.
Appellant was detained and medicated for 6 months and 18 days, discharged on 7 June 1997 as fit to stand trial.

On 12 August 1997, Guillermo pleaded not guilty but admitted killing Erlinda, raising the defense of insanity.
Witnesses testified to appellant’s odd behavior prior to the incident (singing, dancing, talking alone), but also socializing and drinking with others.
The trial court received a letter for Guillermo’s recommitment due to unstable mental condition but later found him fit to stand trial.
Appellant testified he had no memory of the killing but recalled events before and after it, including being brought to jail and recognizing his children.
Based on testimony and evidence, the trial court convicted Guillermo of parricide with the aggravating circumstance of cruelty and sentenced him to death, ordering indemnification to the heirs of Erlinda.

Whether appellant Guillermo Florendo is exempt from criminal liability due to insanity at the time of the crime.
Whether the aggravating circumstance of cruelty applies to the killing.
Whether the relationship between Guillermo and Erlinda was that of legal spouses to sustain the charge of parricide.
Proper penalty to be imposed considering the circumstances.
Whether indemnification should be awarded to the heirs of the victim.