G.R. No. 9265 - People vs Guevara

The defendant, Jose Guevara, was arraigned and duly tried for the crime of parricide.
The case was heard by the Court of First Instance of Tayabas, which issued a judgment on August 14, 1913.
The judgment imposed the penalty of life imprisonment, required payment of costs, and mandated indemnity to the heirs of the deceased in the sum of P1,000.

The incident occurred on Palm Sunday, March 16, 1913, at around noon.
The location of the crime was the residence of Miguela Soldevilla in the barrio of Banuyo, in the town of Gasan, Tayabas.
At the time of the incident, the defendant resided with his wife, the deceased Ignacia Salvacion.
While Mrs. Salvacion was engaged in starching clothes, the defendant attacked her using a bolo.

A deep, fatal wound was inflicted on the left side of the victim’s forehead—a 5-inch cut that penetrated her skull and brain.
A serious, though non-fatal, 4-inch wound was caused on her neck, which did not sever the bone.
A 6-inch deep wound was inflicted on the right shoulder at the point where it joins the arm, cutting through the muscles.
Additionally, the victim received two minor cuts on the lower and posterior portion of her forearm.
The wounds, particularly the deep cranial cut, eventually led to her death on April 24, 1913.

The prosecution’s evidence established, beyond all reasonable doubt, that the defendant was the author of the crime.
Witness testimonies described the defendant’s actions and demeanor before, during, and after the crime.
Testimony by Miguela Soldevilla (the victim’s mother) confirmed that shortly before the incident the defendant behaved normally by advising her to take a bath.
The victim’s mother also noted that the defendant had shown signs of jealousy, evidenced by his request for her to accompany him to the barrio of Dawis three days prior to the crime.

It was argued that the evidence presented in the lower court, which suggested insane behavior, was based on observations made after the commission of the crime, not at the moment of the act.

Multiple witnesses testified regarding the defendant’s behavior while detained in the municipal jail of Gasan.

Doctor Villanueva observed behaviors consistent with possible insanity, such as complaints of insomnia and a peculiar questioning about remedies.
The president of the board of health, Julian Pilares, provided detailed observations:

He saw the defendant in ostensibly abnormal situations—bare, lying face down, and even swimming in his own urine.
However, Pilares’ later testimony indicated that the defendant was coherent, reading, studying, and responding effectively during subsequent observations.
Pilares also mentioned that a blood analysis ordered from the Bureau of Health in Manila returned negative for any illness or mental instability.

The defendant’s mother-in-law corroborated that for over a month and a half prior to the event, the defendant showed no signs of fever or abnormal behavior while living with the family.
The cumulative evidence led to the conclusion that any erratic behavior noted during arrest was likely feigned or a reaction to the gravity of the crime, rather than genuine insanity.

Whether the act committed by the defendant constitutes parricide under the applicable law.
Whether the defense’s claim of insanity is a valid ground for exempting the defendant from criminal responsibility.
Whether the imposition of the penalty of life imprisonment, along with ancillary penalties (indemnity and costs), was appropriate given the facts and evidence.