G.R. No. 4912 - People vs Guy-Sayco

Gelasio Galupitan, the husband of the accused Emilia Guy-Sayco, had entered into an unlawful relationship with the deceased, Lorenza Estrada.
All principal parties (Gelasio, Emilia, and Lorenza) were residents of Santa Cruz, the capital town of the Province of La Laguna.

Emilia Guy-Sayco became aware of her husband’s affair well before the commission of the crime.
Her husband had been absent from home for more than two weeks, reportedly staying in the barrio of Dujat—a location about two and one-half hours’ walk from Santa Cruz—under the guise of being engaged in field work.
On March 20, 1907, at around 2 p.m., Emilia, determined to join her husband in the barrio, hired a carromata.
She procured necessary clothes and other items for herself and her husband, and she set out along with her infant child and a servant girl.

Before reaching her destination, night fell, and at about 7 p.m. Emilia alighted from the vehicle, dismissed the driver after paying him, and prepared to continue her journey on foot.
For fear of being attacked en route, she disguised herself by donning her husband’s clothes and a hat provided by her companion.
Upon noticing her husband’s horse tied in front of a low house, she suspected his presence inside.
She approached the steps of the house and observed her husband sitting with his back turned towards the entry.

Emilia entered the house and was confronted with the scene of her husband dining with the deceased, Lorenza Estrada, and the owners of the house.
Overcome by jealousy, she immediately attacked Lorenza with a penknife that she carried.
In the struggle, Emilia inflicted five wounds upon Lorenza, one of which, located on the left side of the breast, penetrated the left ventricle of the heart and was deemed of necessity mortal.
Lorenza collapsed, covered with blood, and died moments later.
After the aggression, Emilia left the scene promptly and proceeded to the house of Modesto Ramos where she changed her clothes.

The following day, a medical examination by Dr. Gertrudo Reyes confirmed that five wounds were present, with one being invariably mortal.
A complaint was filed by the provincial fiscal on May 31, 1907, and proceedings were duly instituted.
On June 29, 1908, the court below rendered judgment sentencing Emilia Guy-Sayco to twelve years and one day of reclusion temporal, along with accessory penalties.
Additionally, she was ordered to indemnify the heirs of the deceased in the amount of P1,000 and to bear the costs.
The judgment was appealed by the accused.

Emilia pleaded not guilty and contended that when Lorenza Estrada, upon seeing her and hearing her remonstrate with her husband, threatened her with a knife, she resorted to what she claimed was proper self-defense.
She alleged that in the ensuing struggle she managed to seize a penknife from the floor and used it in an act of self-defense.
Her counsel emphasized that the act was committed under duress, asserting that she was a victim of an imminent attack.

Whether the killing of Lorenza Estrada qualifies as homicide as defined under Article 404 of the Penal Code, or if it should be treated as assassination under Article 403, which carries a heavier penalty.

Whether Emilia Guy-Sayco’s allegation of self-defense can be sustained under the provisions of Article 8, No. 4 of the Penal Code, given the circumstances observed at the scene.

Whether the mitigating circumstance (No. 7 of Article 9 of the Penal Code) — acting upon the impulse of passion and under great jealous excitement — should be considered in reducing the penalty.

Whether the accused’s criminal act should also render her civilly liable for damages under Article 17, as well as if the court properly regulated the indemnity amount pursuant to Article 122 of the Penal Code.