G.R. No. L-9625; August 22, 1914
THE UNITED STATES, plaintiff-appellee, vs. JOSE GUEVARRA, defendant-appellant.

FACTS:
On March 16, 1913, in the barrio of Banuyo, Gasan, Tayabas, the defendant, Jose Guevarra, attacked his lawful wife, Ignacia Salvacion, with a bolo while she was starching clothes. He inflicted multiple wounds, including a deep and fatal wound on her forehead that penetrated her skull and brain. His wife died from these wounds on April 24, 1913. Guevarra fled after the attack but was later apprehended. At his trial for parricide in the Court of First Instance of Tayabas, he was found guilty and sentenced to life imprisonment, indemnification of the heirs, and payment of costs. The defense attempted to prove that Guevarra was insane at the time of the crime, presenting evidence of erratic behavior he exhibited after his arrest, such as shouting incoherently and appearing disoriented in jail. However, no evidence was presented to establish that he was insane prior to or at the very moment of the killing. The trial court rejected the insanity defense. Guevarra appealed the judgment.

ISSUE:
1. Whether the crime committed was correctly classified as parricide.
2. Whether the defendant’s alleged insanity at the time of the crime was sufficiently proven to exempt him from criminal liability.
3. Whether the penalty of life imprisonment was correctly imposed.

RULING:
The Supreme Court AFFIRMED the judgment of the trial court in all respects.
1. On the Classification of the Crime: The crime was properly classified as parricide. It was proven and admitted that Guevarra was lawfully married to the victim and that the marriage was subsistent at the time of the killing. He inflicted the fatal wounds that caused her death, satisfying all the elements of the crime of parricide under Article 402 of the Penal Code.
2. On the Insanity Defense: The defense of insanity was not duly proven. The legal presumption is that a person acts with sound mind. The burden was on the defense to prove that the defendant was insane at the time of the commission of the crime. The evidence presented only pertained to his behavior after the crime, which could have been feigned upon realizing the gravity of his act or could have been the effect of conscience. Testimony from the president of the local board of health, who observed the defendant by court order, ultimately stated that in his observations, the defendant showed no abnormality, answered questions rationally, and never appeared in an irrational condition. Furthermore, the mother of the victim testified that in the month and a half preceding the crime, the defendant showed no signs of insanity, though he did appear jealous. The Court found no error in the trial court’s rejection of this defense.
3. On the Penalty: The penalty of cadena perpetua (life imprisonment) is the lesser of the two indivisible penalties prescribed for parricide under the Penal Code at that time. No mitigating or aggravating circumstances were found to be present. Therefore, the penalty was imposed correctly, along with the corresponding accessories, indemnity, and costs.