G.R. No. L-15177, December 18, 1919
THE UNITED STATES, plaintiff-appellee, vs. ALEJANDRO AGATEA, defendant-appellant.

FACTS:
The defendant-appellant, Alejandro Agatea, was charged with and convicted of the crime of parricide for killing his wife, Beatriz Fernando. The evidence established that Agatea developed an illicit relationship with his sister-in-law, Lorenza Fernando, who suggested that they could be together if his wife were dead. Acting on this, Agatea armed himself with a bolo, waited for his wife and her sister Aurea Fernando in an isolated area at night, and attacked them. He killed his wife first and then pursued and killed Aurea. The prosecution’s principal evidence was an extrajudicial confession (an affidavit) executed by Agatea before the justice of the peace of Zamboanga, wherein he detailed the planning and execution of the crimes. The defense contested the admissibility of this confession.

ISSUE:
1. Whether the extrajudicial confession of the accused was admissible as evidence.
2. Whether the trial court correctly appreciated the qualifying and aggravating circumstances and correctly denied the mitigating circumstance of lack of education.

RULING:
The Supreme Court affirmed the judgment of the trial court.

1. On the Admissibility of the Confession: The Court held the extrajudicial confession was admissible. It was made voluntarily, as attested by the confession itself and the testimony of the justice of the peace and police officers. The Court ruled that an extrajudicial confession is not rendered inadmissible merely because the accused was not cautioned that he need not talk or that his statements could be used against him. Furthermore, the confession was corroborated by other evidence, including the accused’s suspicious behavior, the location and condition of the bodies, the wounds matching the bolo used, and bloodstains found on the bolo and the accused’s clothing.

2. On the Circumstances and Penalty: The Court found that the circumstances of known premeditation, treachery (alevosia), nocturnity, and the crime being committed in an uninhabited place (despoblado) were correctly appreciated. The planning with his paramour, the selection of a remote location at night, and the sudden attack on unsuspecting victims clearly established these circumstances. The Court also upheld the trial court’s denial of the mitigating circumstance of lack of instruction under Article 11 of the Penal Code, agreeing that the accused’s ability to understand Spanish and his demeanor indicated he was not an ignorant man.

Consequently, the Supreme Court affirmed the death penalty imposed by the trial court for the crime of parricide.