G.R. No. L-13219-20; August 31, 1960
People of the Philippines, plaintiff-appellee, vs. Remigio Cruz, defendant-appellant.

FACTS

The accused-appellant, Remigio Cruz, was convicted by the Court of First Instance of Nueva Ecija for the crimes of parricide and frustrated murder. He was sentenced to reclusion perpetua for parricide and an indeterminate penalty for frustrated murder, plus indemnities and costs. The appellant was married to Natividad Concepcion in March 1953. Their relationship was tumultuous, with Natividad leaving him on several occasions due to physical abuse. In June 1956, after bringing his wife and sick daughter to his parents’ home in Sta. Rita, Pampanga, he discovered they had left for Cabanatuan City, which enraged him. On June 9, 1956, he followed them to his in-laws’ house in Cabanatuan City. From June 9 to 11, he helped with household chores, was polite, and tried to convince his wife to return to Manila. On the night of June 11, 1956, after Natividad’s father left for work and her sisters went upstairs to sleep, the appellant and Natividad remained on the ground floor. Around midnight, the sisters were awakened by noises. Upon rushing down, they saw the appellant holding a bolo and talking with Natividad. When Anita Concepcion approached, the appellant began hacking Natividad. Anita and her sister Lourdes ran out for help, but the appellant chased and overtook Anita, hacking her on the head until she lost consciousness. Their uncle, Daniel Cabunta, intervened, wrestled the bolo away, and the appellant fled. He was intercepted by Policeman Pedro Villanueva, to whom he stated he was “very much aggrieved,” and was subsequently jailed. The appellant raised several defenses on appeal, including questioning the proof of his marriage to establish parricide, contesting the finding of treachery, and claiming insanity at the time of the crimes based on a history of schizophrenia diagnosis and confinement in 1948, his violent reactions to his wife’s departure, and his actions during the incident.

ISSUE

1. Whether the fact of marriage was sufficiently proven to sustain a conviction for parricide.
2. Whether treachery attended the assault on Anita Concepcion.
3. Whether the appellant was insane at the time of the commission of the crimes, constituting an exempting circumstance.

RULING

1. On the proof of marriage: The Court held that the fact of marriage was sufficiently established. While the best proof is a marriage certificate, the oral evidence presented to prove the marriage was not objected to during trial. Citing jurisprudence and legal commentary, the Court ruled that evidence introduced without objection becomes part of the case and can be considered by the court.
2. On the presence of treachery: The Court found the appellant’s assault on Anita Concepcion to be treacherous. The attack was sudden and unexpected, as Anita was running away and crying for help when the appellant chased and overtook her to strike her on the head, ensuring the execution of the crime without risk to himself.
3. On the plea of insanity: The Court rejected the defense of insanity. The law presumes all acts to be voluntary, and insanity must be clearly proved as a complete deprivation of intelligence or discernment at the time of the act. Mere abnormality or a history of mental illness is insufficient. The Court noted that in the days preceding the crimes, the appellant was polite, helpful, and rational in pleading with his wife. After the crimes, he fled instinctively, gave a responsive answer to the policeman (“aggrieved”), and surrendered. Medical reports indicated he could recount important life events. His violent acts, such as smashing dishes and the jar, were deemed demonstrations of an explosive temper and passion over his wife’s refusal to reconcile, not clear proof of insanity or a deprivation of consciousness. Therefore, he was not entitled to the exempting circumstance.
The decision of the lower court was affirmed in all respects.