G.R. No. L-3246; November 29, 1950
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ABELARDO FORMIGONES, defendant-appellant.

FACTS

The appellant, Abelardo Formigones, was convicted of parricide for stabbing his wife, Julia Agricola, to death on December 28, 1946. The killing was witnessed by their daughter. The motive was jealousy, as the appellant suspected his wife of having an illicit relationship with his half-brother. During the preliminary investigation, he pleaded guilty but entered a plea of not guilty at trial. His defense was based on imbecility under Article 12 of the Revised Penal Code, claiming exemption from criminal liability. Evidence showed he behaved strangely in jail, but the prosecution’s medical expert testified he was only feebleminded and could distinguish right from wrong.

ISSUE

Whether the appellant is an imbecile exempt from criminal liability under Article 12 of the Revised Penal Code.

RULING

No. The Supreme Court affirmed the conviction. For imbecility to be an exempting circumstance, there must be a complete deprivation of intelligence, discernment, and freedom of will at the time of the crime. The appellant’s feeblemindedness, ability to work, support his family, and feel jealousy indicated he was not completely deprived of reason. His strange behavior in jail was attributed to remorse or eccentricity, not insanity. The penalty of reclusion perpetua was affirmed, but the Court, invoking Article 5 of the Revised Penal Code, recommended executive clemency to the Chief Executive for a possible reduction of the penalty, considering the circumstances.

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