G.R. No. L-27031 - People vs. Renegado y Senora

Mamerto de Lira was a mathematics teacher at Tiburcio Tancinco Memorial Vocational School in Calbayog City.
Loreto Renegado, an employee of the same school, worked as a clerk with duties including typing various documents and managing school records.
On August 29, 1966, within the school premises, Renegado stabbed de Lira, inflicting wounds that led to de Lira’s death on September 4, 1966.

A periodical test was scheduled for September 2, 1966; teachers were instructed to submit test questions for typing by August 25-26.
On August 26, 1966, de Lira requested Renegado to type the stencil of his test questions at the school canteen.
Renegado declined, citing workload in the principal’s office and denying typing test questions as his duty.
De Lira reminded Renegado of the principal’s instruction to assist teachers in typing if needed and advised him to work diligently.
Renegado became angry, showed hostile behavior by punching a cabinet, and departed the canteen.

Renegado expressed to school security guard Primitivo Velasco his intent to kill someone, which Velasco discouraged.
He also confided in employee Basilio Ramirez his plan to kill de Lira, who dissuaded him.
Renegado cycled around the school during a dance on the evening of August 26, asking a security guard if de Lira was present.
Teacher Arturo Querubin noticed Renegado’s suspicious behavior and warned him to calm down for the sake of his family.
On August 29, Renegado made a remark to bookkeeper Erlinda Rojo suggestive of violent intentions toward de Lira.

Around 9:30 A.M. on August 29, de Lira was drinking at the school canteen when Renegado entered.
Renegado stabbed de Lira from behind in the right lumbar region without warning.
De Lira raised a chair to defend himself, but Mrs. Tan intervened, shouting at Renegado to stop.
Renegado desisted and fled the scene.
De Lira was taken to Calbayog City General Hospital, where surgery was performed. The wound penetrated the right lower lobe of the liver, resulting in internal hemorrhage and eventual death due to hepatic insufficiency.

Renegado claimed provocation by de Lira’s aggression, alleging that de Lira physically assaulted him first and threatened to kill him.
He recounted his submission to the principal and attempted to minimize his intent by stating he lost consciousness ("lost his senses") at the moment of stabbing.
He denied premeditation and portrayed the stabbing as an impulsive act under confusion.
Renegado called witnesses to support his version, including Manuel Cordove who attested that Renegado was standing ahead of de Lira in the canteen before the stabbing.

Evidence was presented that Renegado suffered a head injury in 1950 from a “clubbing,” which allegedly caused temper disturbances.
Testimony revealed episodes of violent temper but no expert evidence or clear proof of insanity.
Wife and relatives testified on his violent temper and family conflicts but could not establish total impairment of mental faculties.

The trial court found Renegado guilty of murder with assault upon a person in authority, with evident premeditation and treachery.
Renegado was sentenced to death and ordered to indemnify the heirs P6,000 plus costs.
The case went for automatic review before the Supreme Court.

Whether appellant Renegado’s plea of insanity and resulting lack of criminal liability is supported by the evidence.
Whether the prosecution witnesses should be believed given claims of bias and improbability of disclosure of intent to kill.
Whether the killing of Mamerto de Lira qualifies as murder with assault upon a person in authority under the Revised Penal Code.
Whether the killing was attended by evident premeditation and treachery.
Whether the assault was committed in the performance of duty or on the occasion thereof, thus qualifying under Article 148 of the Revised Penal Code.