Case Summary (G.R. No. L-13219-20)
Background of the Case
Remigio Cruz was charged with parricide and frustrated murder. He was convicted and sentenced to reclusion perpetua for the parricide of his wife, Natividad, and to an indeterminate sentence for the frustrated murder of his sister-in-law, Anita. The court also imposed civil indemnities to the heirs of the victims. The appellant contested his conviction through an appeal, arguing various points that underpin the case.
Relationship and Events Leading to the Crime
The marriage between Cruz and Natividad commenced in March 1953, but it was fraught with conflict, including physical abuse that prompted Natividad to leave him multiple times. Tensions escalated such that, on June 11, 1956, Cruz followed Natividad and their daughter to her parents’ home in Cabanatuan City. After strained interactions, an altercation arose between Cruz and Natividad, culminating in Cruz attacking both Natividad and Anita with a bolo.
Evidence Presented
During the trial, oral testimonies were admitted to prove the existence of Cruz’s marriage, overcoming the appellant's argument concerning the absence of a marriage certificate. Witnesses recounted the violent incident, including Cruz's sudden attack on his wife, which indicated his intent and state of mind during the commission of the crimes.
Defense Arguments
Cruz’s defense included claims of insanity at the time of the offenses, citing past hospitalizations for schizophrenia. He argued that his mental condition excused him from liability for the violent acts. However, the court emphasized the necessity of proving insanity as a complete deprivation of reason, which did not align with Cruz's behavior prior to and following the assaults.
Court's Findings on Insanity
The court assessed Cruz's mental state against the legal standard for insanity. It underscored that proof of insanity must demonstrate an absence of discernment during the commission of the act. Despite previous mental health issues, evidence revealed that Cruz was functioning ad
...continue readingCase Syllabus (G.R. No. L-13219-20)
Case Background
- The accused, Remigio Cruz, was indicted in the Court of First Instance of Nueva Ecija for two separate crimes: parricide and frustrated murder.
- The accused was convicted and sentenced to reclusion perpetua for the crime of parricide and an indeterminate penalty for frustrated murder, ranging from 2 years, 4 months, and 1 day of prision correccional to 8 years of prision mayor.
- Additionally, he was ordered to indemnify the heirs of the victims, Natividad Concepcion and Anita Concepcion, in the amounts of P6,000.00 and P2,000.00, respectively, along with the payment of costs.
- The appellant subsequently appealed the conviction.
Marital Relations and Domestic Context
- Remigio Cruz married Natividad Concepcion in March 1953, and they resided in Manila with Natividad’s parents.
- They had a daughter born in 1954, after which Natividad separated from Remigio due to allegations of domestic violence.
- The couple reconciled temporarily but experienced further separations, with Natividad moving back to her parents' home in Cabanatuan City in 1955.
Incident Leading to the Crimes
- In June 1956, Remigio took his wife and sick daughter to his parents' home in Sta. Rita, Pampanga.
- Upon returning from fetching a doctor for his daughter, he discovered that Natividad and their daughter had left for Cabanatuan City again.
- Enraged, he followed them, and from June 9 to June 11, 1956, he behaved normally, assisting with househ