Facts:

In the case of The United States vs. Pablo Guevara, G.R. No. 4153, decided on January 25, 1908, the defendant, Pablo Guevara, was charged with the murder of his lawful wife. The trial took place in the Philippines, where Guevara was found guilty and subsequently sentenced to life imprisonment. The court also imposed accessory penalties as prescribed by Article 54 of the Penal Code, which included an indemnity of 1,000 pesos to the heirs of the deceased and the payment of trial costs. The prosecution's case was significantly supported by confessions made by Guevara both before and during the trial. During the proceedings, Guevara recounted the events leading to the crime, attempting to invoke the mitigating circumstance of self-defense. However, the lower court did not consider this defense, and thus, the appellate court also refrained from addressing it. The facts revealed that the deceased had been involved in an adulterous relationship, which was corroborated by the t...

Facts:

1. Accused and Victim: The accused, Pablo Guevara, was convicted of killing his lawful wife.
2. Confessions: The crime was fully proven through confessions made by the accused both before and during the trial.
3. Defense Claim: The accused attempted to justify his actions by invoking self-defense, but this claim was not considered by the lower court.
4. Provocation by the Deceased: The deceased (the accused's wife) had been convicted of adultery and lived an unchaste life with her lover, who testified during the trial. She also attempted to take away their only daughter by filing a complaint against the accused.
5. Immediate Provocation: The deceased's actions, including her efforts to take their daughter and her unchaste behavior, were deemed immediate provocation, leading the accused to act in a sudden fit of rage.
6. Crime Committed: The accused followed his wife to her home and killed her in an act of revenge.

Issue:

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Ruling:

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Ratio:

1. Self-Defense Claim: The Court did not consider the accused’s claim of self-defense, as it was not supported by the facts and was not taken into account by the lower court.
2. Penalty for Parricide: Under Article 402 of the Penal Code, parricide (killing one’s spouse) is punishable by life imprisonment.
3. Mitigating Circumstances: Although the Court acknowledged the presence of two qualifying mitigating circumstances (immediate provocation and loss of reason due to the deceased’s actions), it ruled that the penalty could not be reduced further under Article 80 of the Penal Code.
4. Discretionary Power: The Court invoked its discretionary power under Article 2 of the Penal Code to recommend a reduction of the penalty to the executive branch, given the excessive nature of the penalty.