Case Digest (G.R. No. L-3246)
Facts:
The People of the Philippines v. Abelardo Formigones, G.R. No. L-3246. November 29, 1950, the Supreme Court En Banc, Montemayor, J., writing for the Court.The appellant, Abelardo Formigones, lived with his wife, Julia Agricola, and five children; they moved from their farm in Bahao, Libmanan (municipality of Sipocot, Camarines Sur) to the house of his half-brother Zacarias Formigones to seek work harvesting palay. On December 28, 1946, late in the afternoon, Julia was sitting at the head of the stairs when Abelardo suddenly took a bolo from the wall and stabbed her in the back; the blade penetrated the right lung and she soon died. Their eldest daughter, Irene, witnessed the stabbing and summoned help. Abelardo picked up his wife, carried her upstairs, laid her on the living-room floor and lay beside her; he was later found in that position by neighbors. Investigated by the Constabulary, Abelardo signed a written confession (Exhibit D) admitting the killing and stating jealousy—suspicion of an illicit relation between his wife and his brother Zacarias—as motive.
At the preliminary investigation before the justice of the peace, the accused pleaded guilty (Exhibit S). At trial in the Court of First Instance of Camarines Sur he pleaded not guilty but did not testify; his counsel offered testimony of two provincial jail guards describing peculiar and sometimes bizarre conduct while imprisoned (stripping, singing, appearing absent-minded). A physician, Dr. Francisco Gomez, examined Abelardo and opined that he was feeble‑minded but not an imbecile, and that he could distinguish right from wrong. The trial court found Abelardo guilty of parricide, sentenced him to reclusion perpetua, ordered indemnity of P2,000 to the heirs, and imposed costs.
The appellant appealed to the Supreme Court, urging that he was an imbecile exempt from criminal responsibility under Article 12, Revised Penal Code. The Supreme Court reviewed the testimonial, medical, and factual record, considered Spanish and Philippine precede...(Pro-only)
Issues:
- Whether the appellant's alleged imbecility (insanity) exempts him from criminal liability under Article 12 of the Revised Penal Code.
- Whether the aggravating circumstance of treachery attended the killing.
- What penalty should be imposed in view of the established mitigating circumstances and the statutory scheme (Articles 63 and 64, Revised Penal Code), and whether legal reduction is available or e...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)