Case Digest (G.R. No. L-3246) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Abelardo Formigones, G.R. No. L-3246, decided on November 29, 1950 under the 1935 Constitution, the appellant Abelardo Formigones lived with his wife Julia Agricola and five children on his farm in Bahao, Libmanan, Sipocot, Camarines Sur, before relocating in mid-December 1946 to his half brother Zacarias Formigones’s house in barrio Binahian to seek work as a palay harvester. On December 28, 1946, late in the afternoon, Abelardo seized a bolo without prior argument and stabbed Julia in the back, the blade penetrating her right lung, causing fatal hemorrhage. Julia toppled down the stairs, whereupon Abelardo bore her upstairs and lay beside her until neighbors, alerted by the shouts of their eldest daughter Irene, arrived. Investigating constabulary officers obtained a written admission of guilt from Abelardo (Exhibit D), and during preliminary inquiry he pleaded guilty (Exhibit S). At trial he retracted his plea but did not testify; his counsel Case Digest (G.R. No. L-3246) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Setting
- Defendant/Appellant: Abelardo Formigones, married to Julia Agricola, father of five children.
- Initial residence: Farm in Bahao, Libmanan, Sipocot, Camarines Sur; later moved to half-brother Zacarias Formigones’s house in Binahian to work as palay harvesters.
- Circumstances of the Crime
- Date and time: Late afternoon of December 28, 1946.
- Incident: Without prior quarrel or provocation, Abelardo took a bolo from the wall and stabbed his wife in the back; the blade penetrated her right lung, causing fatal hemorrhage.
- Aftermath: Julia Agricola fell down the stairs; Abelardo carried her back upstairs, laid her in the living room, and lay beside her.
- Discovery and Investigation
- Eyewitness: Eldest daughter Irene witnessed the stabbing and summoned neighbors with her cries.
- Constabulary inquiry: Abelardo was arrested; he signed written confession (Exhibit D) admitting the killing, attributing motive to jealousy over suspected illicit relations between his wife and brother.
- Preliminary hearing: Before the Justice of the Peace of Sipocot, the accused pleaded guilty (Exhibit S).
- Trial Proceedings and Defense
- Court of First Instance: Abelardo pleaded not guilty and did not testify.
- Defense evidence: Two jail guards described his “strange” conduct—nakedness, silence, singing, escape attempt—suggesting possible insanity or feeble-mindedness.
- Appeal basis: Claim of imbecility exempting him from criminal liability under Article 12 of the Revised Penal Code.
Issues:
- Exemption from Criminal Liability
- Whether appellant’s mental condition (feeble-mindedness) rises to imbecility or insanity under Art. 12, RPC, to absolve liability.
- Aggravating Circumstance of Treachery
- Whether treachery attended the killing such that penalty enhancement is warranted.
- Mitigating Circumstances and Penalty
- Whether appellant’s feeble-mindedness and impulsive passion constitute mitigating circumstances meriting reduction of penalty under Arts. 13 and 63, RPC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)