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### Facts
In November 1946, Abelardo Formigones was living on his farm in Bahao, Libmanan, in the municipality of Sipocot, Camarines Sur, with his wife Julia Agricola and their five children. They moved to the house of Abelardo’s half-brother, Zacarias Formigones, in the barrio of Binahian to find employment as harvesters of palay. After about a month, on December 28, 1946, Abelardo, without any provocation, took his bolo and stabbed Julia, piercing her right lung. Julia fell down the stairs and died from a severe hemorrhage shortly after.
Their eldest daughter, Irene Pormigones, witnessed the event and shouted for help, prompting neighbors to arrive and find Abelardo lying beside his deceased wife. Abelardo signed a confession admitting the killing, citing jealousy and suspicion of his wife’s infidelity with his brother Zacarias as the motive.
During the preliminary investigation, Abelardo pleaded guilty but later pleaded not guilty at the Court of First Instance, where his counsel presented jail guards’ testimony about his strange behavior to support a defense of imbecility under Article 12 of the Revised Penal Code.
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### Issues
1. **Whether Abelardo Formigones is exempt from criminal liability due to imbecility under Article 12 of the Revised Penal Code.**
2. **Determination of the appropriate penalty for parricide under the Revised Penal Code considering the presence of mitigating circumstances and absence of aggravating circumstances.**
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### Court’s Decision
**Issue 1:** **Imbecility Defense**
The Supreme Court agreed with the lower court that Abelardo Formigones did not qualify as an imbecile under Article 12 of the Revised Penal Code. According to their analysis and expert testimony from Dr. Francisco Gomez, Abelardo was feeble-minded but not completely deprived of reason or discernment necessary to be considered an imbecile. His jealousy-derived behavior and previous life actions, such as supporting his family and working, indicated that he had some degree of reason and discernment.
**Issue 2:** **Appropriate Penalty**
The penalty for parricide under Article 246 of the Revised Penal Code is reclusion perpetua to death. The presence of two mitigating circumstances—feeble-mindedness and passion or obfuscation due to jealousy—without any aggravating circumstances, was acknowledged by the Court. Applying Article 63, Rule 2, the Court sustained the imposition of reclusion perpetua, but noted that the executive branch may apply clemency based on Abelardo’s demonstrated remorse and feeble-minded state.
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### Doctrine
– **Imbecility under Article 12:** Imbecility or insanity must deprive the person completely of reason or free will at the time of the crime to exempt them from criminal liability. Feeble mindedness does not exempt one from criminal responsibility.
– **Mitigating Circumstances:** The Court recognized the mitigating circumstances of feeble-mindedness and acting upon jealousy as factors that reduce moral culpability, influencing the imposition of the lighter penalty of reclusion perpetua.
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### Class Notes
1. **Article 12, Revised Penal Code:** Exempts from criminal liability persons absolutely deprived of reason or free will due to insanity or imbecility.
2. **Article 13, Revised Penal Code:** Mitigating circumstances that can lessen the penalty, such as acting due to passion or suffering from a mental defect that diminishes willpower.
3. **Article 63, Revised Penal Code:** Defines the application of indivisible penalties, noting appropriate penalty adjustments based on mitigating or aggravating circumstances.
4. **Significant Cases:**
– **U.S. vs. Vaquilar**: Testimonies that indicate mental disturbances must incontrovertibly prove insanity at the time of crime to accept such a defense.
– **People vs. Castañeda**: Court’s delineation of mitigating circumstances without aggravating circumstances leading to imposition of lesser penalties.
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### Historical Background
This case occurred in the post-World War II era when the Philippine legal system was addressing complex societal shifts and issues such as mental health in criminal defenses. During this time, courts were active in interpreting the newly codified provisions of the Revised Penal Code to apply traditional legal principles to evolving societal challenges. The recognition of mental health concerns alongside criminal responsibilities was a developing aspect of Philippine jurisprudence.
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