G.R. No. L-4153 - People vs Guevara

The accused, Pablo Guevara, was convicted of killing his lawful wife.
He was sentenced to life imprisonment, along with accessory penalties as prescribed by Article 54 of the Penal Code.
The court ordered Guevara to indemnify the heirs of the deceased in the amount of P1,000 and to cover burial costs.
The prosecution's case was substantiated by confessions made by Guevara both before and during the trial.

During the trial, Guevara attempted to assert a defense of self-defense, recounting the events leading to the crime.
The lower court did not consider this self-defense argument, and consequently, the appellate court also refrained from addressing it.
The court noted that the confessions provided a clearer understanding of the circumstances that led to the crime, including the emotional turmoil experienced by Guevara.

The deceased had been convicted of adultery and had lived an unchaste life, which contributed to the provocation of Guevara.
The deceased attempted to take custody of their only daughter by filing a complaint against Guevara, which further incited his anger.
The court found that the actions of the deceased constituted immediate provocation, leading to Guevara's decision to seek revenge.

The penalty imposed aligns with Article 402 of the Penal Code, which prescribes life imprisonment for parricide, including the killing of a spouse.
Article 80, paragraph 2, states that in cases with two indivisible penalties (life imprisonment and death), if there are mitigating circumstances without aggravating ones, the lesser penalty should apply.
Despite the presence of two qualifying mitigating circumstances, the court ruled that the penalty could not be reduced to a lesser one due to the specific provisions of the law.