Case Summary (G.R. No. 130627)
Facts of the Case
In June 1929, the family was experiencing domestic turmoil. Eladio Castaneda, while intoxicated, threatened his wife, Maria Fontillas, leading her to seek refuge in the home of another son, Felixberto. Severino, following his parents, armed himself with a piece of wood. When Eladio confronted Felixberto, Severino struck him on the head with the wood, resulting in a fatal skull fracture and subsequent death from cerebral hemorrhage.
Trial Court Proceedings
Severino Castaneda and Felixberto were charged with parricide; however, the prosecution did not establish a conspiracy between them. The evidence indicated that each acted independently: Felixberto struck Eladio first, followed by Severino's fatal blow. Despite Felixberto's actions, there was no evidence linking his blow to the cause of death.
Severino's Plea and Defense
During his arraignment, Severino pleaded guilty but sought to establish mitigating circumstances, claiming he acted to protect his mother, that he lacked intent to cause serious harm, and that he was provoked. The court found no merit to his self-defense claim, stating Eladio posed no imminent threat at that moment.
Mitigating Circumstances
The court recognized certain mitigating circumstances during the commission of the offense, including Severino’s plea of guilt, lack of intent to commit a grave wrong, and lack of prior conviction. However, there were no aggravating factors against him.
Application of the Law
Under Article 246 of the Revised Penal Code, the penalties for parricide are reclusion perpetua to death. The presence of mitigating factors necessitated applying the lesser penalty as prescribed under Article 63(3), which states that if mitigating circumstances are present without aggravating circumstances, the le
...continue readingCase Syllabus (G.R. No. 130627)
Background of the Case
- The case revolves around the conviction of Severino Castaneda for the crime of parricide in the Court of First Instance of Zambales.
- The incident occurred in June 1929, involving Severino, his father Eladio Castaneda, and his mother Maria Fontillas.
- Eladio Castaneda, while intoxicated, was involved in a heated argument with his wife, during which she sought refuge in the house of another son, Felixberto Castaneda.
Incident Details
- During the confrontation, Eladio Castaneda followed Maria and attempted to confront her.
- Severino Castaneda armed himself with a piece of wood and struck his father on the head, resulting in a fatal injury.
- The prosecution presented evidence that Severino's blow caused a skull fracture leading to cerebral hemorrhage, which ultimately caused Eladio's death.
Legal Proceedings
- The prosecution filed charges against both Severino and Felixberto Castaneda, but there was no evidence of conspiracy between the two.
- It was established that both defendants acted independently during the incident, with Felixberto delivering a fist blow while Severino delivered the fatal blow with the piece