THIRD DIVISION
APRIL 25, 2018
G.R. No. 219113
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee
vs
ROLAND MIRAÑA Y ALCARAZ, Accused-Appellant
DECISION
MARTIRES, J.:
On automatic review before this Court is the 7 August 2014 Decision rendered by the Court
1
of Appeals (CA) in CA-G.R. CR.-H.C. No. 06183, which affirmed the 11 April 2013
Decision of the Regional Trial Court, Branch 30 (RTC), of San Jose, Camarines Sur, in
2
Criminal Case No. T-3231 finding accused-appellant Roland Miraña y Alcaraz (accused-
appellant) guilty beyond reasonable doubt of the crime of Murder and thereby sentencing
him to reclusion perpetua.
Accused-appellant was charged in an Information which reads as follows:
3
That on or about the 17th day of June 2008 at around 6:30 o'clock in the morning in
Barangay San Ramon, Municipality of Lagonoy, Province of Camarines Sur, Philippines and
within the jurisdiction of this Honorable Court, the above-named accused, while armed with
a bolo, with intent to kill and with abuse of superior strength, did then and there, wilfully,
unlawfully and feloniously attack, assault, stab and hack one Dominga Agnas V da. De
Globo, a seventythree year old woman, on the different parts of her body, resulting [in] her
death to the prejudice of her heirs.
The crime is committed with the attendant qualifying circumstance of abuse of superior
strength.
When arraigned on 21 January 2009, accused-appellant entered a plea of not guilty. In view
of accused-appellant's admission that he caused the victim's death, a reverse trial ensued. 4
Version of the Prosecution
Dominga Agnas Vda. de Globo (the victim) was a 73-year-old widow and resident of
Barangay San Ramon, Lagonoy, Camarines Sur. She was also known as "May Inggay" by
her relatives and neighbors. She lived on her own but prior to her death, she frequently
slept at the house of Alberto Mirafia (Alberto), her first cousin, because accused-appellant
had been harassing her, such as by throwing stones at her. The victim believed that
accused-appellant was threatening her because she once reprimanded him after she
caught him stealing fruits from her property.
5
On 16 June 2008, when Alberto returned home from attending a fiesta, he found the victim
in his house, trembling while praying. She told Alberto that she was scared because
accused-appellant had chased her with a bolo. Alberto invited her to sleep in his house and
advised her to report the incident to the barangay. The victim, however, rejected the idea
because accused-appellant was her relative. Thereafter, the victim left Alberto's house and
proceeded to her brother's house. After relating the incident to her brother, she was once
again advised not to go back to her house and to report the incident to the barangay.
Unfortunately, the victim did not heed the advice. She then returned to her house to await
the call of her son, who was working abroad. 6
Between 6 o'clock to 6:30 in the morning of 17 June 2008, Armando Orce (Armando), the
victim's neighbor, was at the coconut plantation near his house when he heard a woman cry
out followed by a loud cry of a man. Believing that the sounds emanated from his house,
Armando immediately ran in that direction. As he came near his house, he saw a woman
lying on her side on the ground in front of the door to his house. Armando recognized the
woman as the victim. He also saw accused-appellant's father crying at the back of their
house facing the accused-appellant. 7
PO3 Bobby Corono (PO3 Corona), together with two (2) other police officers, responded to
a call about the incident. Upon arrival at the place of the incident, PO3 Corono saw the body
of the victim lying on the ground. Accused-appellant approached PO3 Corono and admitted
he was responsible for the victim's death. He then pointed to a bolo and said that he used it
to hack the victim and washed it afterward. PO3 Corono thereafter arrested accused-
appellant and brought him to the police station along with the bolo as evidence. 8
Ramiro Globo (Ramiro), the victim's son, flew back to the Philippines when he found out
9 10
about his mother's death. He visited the mental hospital where accused-appellant was
committed. When asked what he did to Ramiro's mother, accused-appellant replied that he
killed her.
Accused-appellant was initially charged with homicide but, upon a Motion to Remand Case
to Prosecution Office for Reinvestigation, the information for homicide was withdrawn. The
Office of the Provincial Prosecutor of Camarines Sur issued a resolution which ordered that
a new information for murder be filed against accused-appellant.
On 20 June 2008, an order for the immediate transfer of the accused to the Bicol Medical
Center Mental Hospital was issued based on the report that he was being violent to himself
and to others at the jail.
Version of the Defense
In the morning of 17 June 2008, Imelda Miraña (Imelda) found out that her son, accused-
appellant, had killed the victim.
Imelda did not know of any personal enmity between accused-appellant and the victim prior
to the incident. She noticed, however, that her son started exhibiting odd behavior after the
latter's nose was bitten by a cousin. Accused-appellant would smile without anyone in front
of him; he would call a chicken late at night; and would keep on saying to himself that the
victim was a witch. After the incident, she observed that accused-appellant just sat inside
their house, staring blankly.
11
A few nights before the incident, Mercy Delfino (Mercy), accused-appellant's sister, noticed
that her brother kept smiling and could not sleep, and kept on saying that the victim was a
witch. He even claimed that he saw the witch in their own backyard. 12
During trial, accused-appellant claimed not to know or recall the events surrounding the
incident, the identity of the victim, and his confinement and treatment at the mental
hospital. 13
The RTC Ruling
The RTC ruled that accused-appellant was not able to prove his defense of insanity, holding
that "while the purported behavior of accused-appellant would suggest an abnormal mental
condition, it cannot however be equated with a total deprivation of will or an absence of the
power to discern, to accept insanity." It thereafter appreciated the aggravating circumstance
of abuse of superior strength to qualify the crime to murder, in consideration of the fact that
the victim was a 73-year-old unarmed woman as against a male assailant in his early
twenties. The dispositive portion of its decision reads as follows:
WHEREFORE, in view of all the foregoing, this Court finds accused Roland Mirafia y
Alcaraz GUILTY beyond reasonable doubt of the crime of Murder under Article 248 of the
Revised Penal Code, and he is hereby sentenced to suffer the penalty of imprisonment [sic]
of Reclusion Perpetua. Likewise, accused is hereby ordered to pay the surviving heir of the
victim the amount of ₱75,000.00 for the civil indemnity, ₱75,000.00 for moral damages,
₱73,397.95 as actual damages as evidenced by the receipts, and ₱30,000.00 as exemplary
damages.
In addition, pursuant to prevailing circumstances, interest at the rate of six percent (6%) per
annum shall be imposed on all damages awarded from the date of the finality of the
judgment until fully paid (People vs. Cabungan, G.R. No. 189355, January 23, 2013).
The accused having been under preventive imprisonment he is entitled to the full credit of
his confinement if he abide of [sic] the rules and regulations imposed therein otherwise he
shall only be entitled to four-fifth [sic] while serving under preventive detention pending trial
of this case.
Accused-appellant appealed before the CA.
The CA Ruling
The CA affirmed the conviction of the accused-appellant, with modification as to the award
of damages. The dispositive portion of its decision reads as follows:
WHEREFORE, premises considered, the instant Appeal is hereby DENIED. Accordingly,
the 11 April 2013 Judgment of the Regional Trial Court of San Jose, Camarines Sur, Branch
30 in Criminal Case No. T-3231 is AFFIRMED with MODIFICATION. Accused-appellant is
sentenced to suffer the penalty of reclusion perpetua without eligibility for- parole. In
addition to other damages awarded by the trial court, Accused-Appellant is ordered to pay
moral damages in the reduced amount of ₱50,000.00.
The CA agreed with the RTC that accused-appellant failed to overcome the presumption of
sanity; and his bizarre acts prior to the incident cannot be considered insanity for the
purpose of exonerating him because not every aberration of the mind constitutes insanity.
Hence, this appeal.
ISSUE
WHETHER OR NOT INSANITY COULD BE APPRECIATED IN ACCUSED-APPELLANT'S
FAVOR IN ORDER TO EXCULPATE HIM FROM CRIMINAL LIABILITY.
THE COURT'S RULING
The Court finds no reason to disturb the judgment of the Court of Appeals in the matter of
accused-appellant's insanity, but finds that he should only be liable for homicide.
The defense failed to prove
accused-appellant's insanity at
the time of the commission of the
crime.
The defense of insanity is in the nature of a confession or avoidance because an accused
invoking it admits to have committed the crime but claims that he should not be criminally
liable therefor because of insanity, which is an exempting circumstance. Consequently, the
14
accused is tried on the issue of sanity alone, and if found to be sane, a judgment of
conviction is rendered without any trial on the issue of guilt.
15
However, an accused invoking the exempting circumstance of insanity bears the burden of
proving it with clear and convincing evidence because every person is presumed sane.
16 17
For the defense of insanity to prosper, it must be proven that the accused was completely
deprived of intelligence, which must relate to the time immediately preceding or
18
simultaneous to the commission of the offense with which he is charged. 19
Since the state of a person's mind can only be judged by his behaviour, establishing the
insanity of an accused requires opinion testimony which may be given by a witness who is
intimately acquainted with the accused, or who has rational basis to conclude that the
accused was insane based on the witness' own perception of the accused, or who is
qualified as an expert, sue as a psychiatrist.20
Taken against the standard of clear and convincing evidence, the proof proffered by the
defense fails to pass muster.
The defense argues that the exempting circumstance of insanity has been sufficiently
proven through the testimonies of Imelda and Mercy, accused-appellant's mother and
sister, respectively, as well as the testimony of Dr. Imelda C. Escuadera (Dr. Escuadera), a
psychiatrist.
Imelda and Mercy testified that accused-appellant believed that the victim was a witch and
that in the days prior to the incident, accused-appellant was behaving oddly, such as smiling
to himself and calling a chicken late at night. Their testimonies, however, fail to shed light on
accused-appellant's mental condition immediately before, during, and immediately after he
committed the crime.
Moreover, unusual behaviors such as smiling to oneself and calling a chicken late at night
are not proof of a complete absence of intelligence, because not every aberration of the
mind or mental deficiency constitutes insanity. The Court has held that "the prevalent
21
meaning of the word 'crazy' is not synonymous with the legal terms 'insane,' 'non compos
mentis,' 'unsound mind,' 'idiot,' or 'lunatic.' The popular conception of the word 'crazy' is
being used to describe a person or an act unnatural or out of the ordinary. A man may
behave in a crazy manner but it does not necessarily and conclusively prove that he is
legally so." In order to be exempt from criminal liability, the accused must be so insane as
22
to be incapable of criminal intent.
23
The defense also argues that Dr. Escuadera's testimony during the hearing to determine
accused-appellant's fitness to stand trial sufficiently points to his insanity at the time he
committed the crime. Dr. Escuadera testified she conducted a psychiatric interview with
accused-appellant on 21 July 2009, and that her findings, embodied in a Mental Status
Examination Report, showed she deemed accused-appellant fit for trial; and that accused-
appellant had a history of mental illness, which she identified as schizoprenia. 24
At the outset, it must be pointed out that Dr. Escuadera's testimony was presented primarily
to prove that accused-appellant was already fit to stand trial. In fact, she was not the one
who conducted the initial examination on accused-appellant upon the latter's commitment to
a mental hospital. The one who did so, a Dr. Chona Belmonte (Dr. Belmonte), was not
presented as witness. More importantly, Dr. Escuadera's testimony on accused-appellant's
previous mental illness does not specifically pertain to the time of the commission of the
crime. Even her medical report on accused-appellant's mental status, for the purpose of
determining his fitness to stand trial, is bereft of any indication that he was completely
deprived of intelligence or discernment at the time he mortally hacked the victim.
Vague references to his history of mental illness and subsequent diagnosis of schizophrenia
do not satisfy the quantum of proof required to exempt accused-appellant from ·criminal
liability, especially since the defense failed to establish that accused-appellant's mental
ailments, if such was the case, related to the time of the commission of the crime.
Accused-appellant's actuations immediately after the incident also negate a complete
absence of intelligence or discernment when he killed the victim. As testified to by PO3
Corono, accused-appellant approached the police officers when they arrived at the crime
scene, told them that he was responsible for hacking the victim, pointed to the bolo he used,
and indicated that he had already washed the weapon. That accused-appellant had the
25
foresight to wash the bolo after killing the victim and, thereafter, the consciousness to
decide to confess to the authorities what he had done upon their arrival, suggest that
accused-appellant was capable of discernment during the time of the incident.
It is clear from the foregoing circumstances that the defense failed to prove accused-
appellant's insanity at the time of the commission of the crime with the requisite quantum of
proof. Consequently, accused-appellant's conviction must be upheld.
Abuse of superior strength
cannot be appreciated,
such that accused-appellant can only be
held liable for homicide,
not murder.
This Court finds that the conviction of the accused-appellant for murder is flawed because
of the erroneous appreciation of abuse of superior strength as a qualifying circumstance.
The Court finds that the presence of this circumstance in the commission of the crime was
not sufficiently proven.
In concluding that such circumstance existed, both the RTC and the CA primarily took into
account the gender and age of the victim, a 73-yearold female, and the accused-appellant,
a male in his early twenties. The Court finds that this is insufficient to conclude the presence
of abuse of superior strength.
It has been stressed that for abuse of superior strength to be properly appreciated as a
qualifying circumstance, it must be shown that the advantage of superior strength was
purposely and consciously sought by the assailant, viz:
Abuse of superior strength is present whenever there is a notorious inequality of forces
between the victim and the aggressor, assuming a situation of superiority of strength
notoriously advantageous for the aggressor selected or taken advantage of by him in the
commission of the crime. The fact that there were two persons who attacked the victim does
not per se establish that the crime was committed with abuse of superior strength, there
being no proof of the relative strength of the aggressors and the victims. The evidence
must establish that the assailants purposely sought the advantage, or that they had
the deliberate intent to use this advantage. To take advantage of superior strength
means to purposely use excessive force out of proportion to the means of defense
available to the person attacked. The appreciation of the aggravating circumstance
depends on the age, size, and strength of the parties. (emphasis supplied)
26
In the present case, the prosecution failed to proffer evidence that accused-appellant
purposely sought such advantage. The testimonies of the witnesses, on the whole, do not
establish that accused-appellant made any conscious effort to use his age, size, or strength
to facilitate the commission of the crime, as in fact the notorious disparity of these factors
between the victim and the accused-appellant was not even clearly shown.
What is only certain herein is that the accused-appellant killed the victim, and the exempting
circumstance of insanity cannot be appreciated in his favor.
In the light of the foregoing, this Court is obliged to rule out abuse of superior strength as a
qualifying circumstance. There being no other circumstance alleged and proven to qualify
the crime to murder, accused-appellant can only be liable for homicide.
As to the award of damages, there is also a need to modify the same, in conformity
with People v. Jugueta, where the Court laid down the rule that in crimes where the death
27
of the victim resulted and the penalty is divisible, such as in homicide, the damages
awarded should be ₱50,000.00 as civil indemnity and ₱50,000.00 as moral damages. This
is apart from the proven actual damages, which the trial court found to amount to
₱73,397.95 undisputed by accused-appellant.
WHEREFORE, the 7 August 2014 Decision of the Comi of Appeals in CA-G.R. CR.-H.C.
No. 06183 is AFFIRMED with MODIFICATION in that accused-appellant Roland Mirafia y
Alcaraz is found GUILTY beyond reasonable doubt of the crime of Homicide under Article
249 of the Revised Penal Code, as amended; and is hereby sentenced to serve the
indeterminate penalty of eight (8) years of prision mayor, as minimum, to fourteen (14)
years, eight (8) months, and one ( 1) day of reclusion temporal, as maximum.
Further, accused-appellant is ordered to pay the heirs of the victim the following amounts:
₱50,000.00 as moral damages, and ₱73,397.95 as actual damages. The award of damages
shall earn interest at the rate of six percent (6%) per annum from the date of finality of the
judgment until fully paid
SO ORDERED.
SAMUEL R. MARTIRES
Associate Justice
WE CONCUR:
PRESBITERO J. VELASCO, JR.
Associate Justice
Chairperson
LUCAS P. BERSAMIN MARVIC M.V.F. LEONEN
Associate Justice Associate Justice
ALEXANDER G. GESMUNDO
Associate Justice
ATTESTATION
I attest that the conclusions in the above Decisionhad been reached in consultation before
the case was assigned to the writer of the opinion of the Court’s Division.
PRESBITERO J. VELASCO, JR.
Associate Justice
Chairperson, Third Division
CERTIFICATION
Pursuant to Article VIII, Section 13 of the Constitution, and the Division Chairperson’s
Attestation, I certify that the conclusions in the above Decision had been reached in
consultation before the case was assigned to the writer of the opinion of the Court’s
Division.
ANTONIO T. CARPIO
Acting Chief Justice
Footnotes
Rollo, pp. 2-13; penned by Associate Justice Florito S. Macalino, with Associate
1
Justices Sesinando E. Villon and Leoncia R. Dimagiba, concurring.
2
CA rollo, pp. 49-57; penned by Presiding Judge Nod D. Paulite.
3
Records. p. I.
4
Records, pp. 124-125.
5
TSN, 24 April 2012, pp. 2-5.
6
Id.
7
TSN, 15 February 2012, pp. 4-10.
8
TSN, 25 July 2012, pp. 2-5.
9
Appears as "Ramero" in some portions of the Records.
10
Appears as "Glovo" in some portions of the Records.
11
TSN, 9 December2009, pp. 3-6.
12
TSN, 10 November 2009, pp. 2-5.
13
TSN, 17 August 2010, pp. 2-5.
14
People v. Tibon, 636 Phil. 521, 530-531 (2010).
15
People v. Roa, G.R. No. 225599, 22 March 2017.
16
Id.
17
Article 800, Civil Code of the Philippines.
People v. Madarang, 387 Phil. 846, 859 (2000), where the Court held that "In the
18
Philippines, the courts have established a more stringent criterion for insanity to be
exempting as it is required that there must be a complete deprivation of intelligence
in committing the act, i.e., the accused is deprived of reason; he acted without the
least discernment because there is a complete absence of the power to discern, or
that there is a total deprivation of the will. Mere abnormality of the mental faculties
will not exclude imputability."
21
People v. Florendo, 459 Phil. 470, 479 (2003).
23
People v. Antonio, Jr., 441 Phil. 425, 429 (2002).
24
TSN, 4 August 2009, pp. 4-7.
25
TSN, 25-July 2012, p. 4.
26
People v. Villanueva, G.R. No. 226475, 13 March 2017.
27
783 Phil. 806 (2016).
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, -versus- ROLAND MIRAÑA Y ALCARAZ,
Accused-Appellant.
G.R. No. 219113, THIRD DIVISION, April 25, 2018, MARTIRES, J.
For the defense of insanity to prosper, it must be proven that the accused was completely deprived of
intelligence, which must relate to the time immediately preceding or simultaneous to the commission
of the offense with which he is charged.
Taken against the standard of clear and convincing evidence, the proof proffered by the defense fails
to pass muster. Imelda and Mercy testified that accused-appellant believed that the victim was a witch
and that in the days prior to the incident, accused-appellant was behaving oddly, such as smiling to
himself and calling a chicken late at night. Their testimonies, however, fail to shed light on accused-
appellant's mental condition immediately before, during, and immediately after he committed the
crime. Moreover, those mentioned unusual behaviors are not proof of a complete absence of
intelligence, because not every aberration of the mind or mental deficiency constitutes insanity.
In addition, Dr. Escuadera testified she conducted a psychiatric interview with accused-appellant on
21 July 2009, and that her findings, showed she deemed accused-appellant fit for trial; and that
accused appellant had a history of mental illness, which she identified as schizophrenia.More
importantly, Dr. Escuadera's testimony on accused-appellant's previous mental illness does not
specifically pertain to the time of the commission of the crime. Even her medical report on accused-
appellant's mental status, for the purpose of determining his fitness to stand trial, is bereft of any
indication that he was completely deprived of intelligence or discernment at the time he mortally
hacked the victim.
Accused-appellant's actuations immediately after the incident also negate a complete absence of
intelligence or discernment when he killed the victim. As testified to by PO3 Corono, accused-appellant
approached the police officers when they arrived at the crime scene, told them that he was responsible
for hacking the victim, pointed to the bolo he used, and indicated that he had already washed the
weapon.The foresight to wash the bolo after killing the victim and, thereafter, the consciousness to
decide to confess to the authorities what he had done upon their arrival, suggest that accused-
appellant was capable of discernment during the time of the incident.
FACTS:
Dominga Agnas Vda. de Globo (the victim) was a 73-year-old widow lived on her own but prior to
her death, she frequently slept at the house of Alberto Mirañ a (Alberto) because accused-appellant
had been harassing her, such as by throwing stones at her. The victim believed that accused-
appellant was threatening her because she once reprimanded him after she caught him stealing
fruits from her property.
Alberto once found the victim in his house trembling while praying. She told Alberto that she was
scared because accused-appellant had chased her with a bolo. Alberto and her brother both advised
her not to go home yet and report the incident to the barangay but she refused. She then went home
to await the call of her son, who was working abroad.
Between 6 o'clock to 6:30 in the morning of 17 June 2008, Armando Orce (Armando), the victim's
neighbor, was at the coconut plantation near his house when he heard a woman cry out followed by
DEAN’S CIRCLE 2019 – UST FCL
27
a loud cry of a man. As he came near his house, he saw the victim lying on her side on the ground.
He also saw accused-appellant's father crying at the back of their house facing the accused-
appellant.
PO3 Bobby Corono (PO3 Corono), with two (2) other police officers, responded to a call about the
incident. Upon arrival, PO3 Corono saw the body of the victim. Accused-appellant approached PO3
Corono and admitted he was responsible for the victim's death; pointed to the bolo he used to hack
the victim which he washed afterwards. PO3 Corono thereafter arrested accused-appellant and
brought him to the police station along with the bolo as evidence. When asked by the victim’s son
what accused-appellant did to his mother, accused-appellant replied that he killed her.
Defense offers that in the morning of the same day, Imelda Mirañ a (Imelda) found out that her son,
accused-appellant, had killed the victim. She did not know of any personal enmity between accused-
appellant and the victim prior to the incident. She noticed, however, that her son started exhibiting
odd behavior after the latter's nose was bitten by a cousin. He would smile without anyone in front
of him; he would call a chicken late at night; and would keep on saying to himself that the victim
was a witch. After the incident, she observed that accused-appellant just sat inside their house,
staring blankly. The same was noticed by the accused-appellant’s sister; that her brother kept
smiling and could not sleep, and kept on saying that the victim was a witch who once was in their
backyard.
During trial, accused-appellant claimed not to know or recall the events surrounding the incident,
the identity of the victim, and his confinement and treatment at the mental hospital. The defense
was insanity.
RTC ruled that accused-appellant was not able to prove his defense of insanity, holding that "while
the purported behavior of accused-appellant would suggest an abnormal mental condition, it
cannot however be equated with a total deprivation of will or an absence of the power to discern, to
accept insanity." It thereafter appreciated the aggravating circumstance of abuse of superior
strength to qualify the crime to murder, in consideration of the fact that the victim was a 73-year-
old unarmed woman as against a male assailant in his early twenties.
CA agreed with the RTC that accused-appellant failed to overcome the presumption of sanity; and
his bizarre acts prior to the incident cannot be considered insanity for the purpose of exonerating
him because not every aberration of the mind constitutes insanity. CA affirmed RTC’s decision with
modification as to the award of damages.
ISSUE:
Whether or not insanity could be appreciated in accused-appellant's favor in order to exculpate him
from criminal liability. (NO)
RULING:
For the defense of insanity to prosper, it must be proven that the accused was completely deprived
of intelligence, which must relate to the time immediately preceding or simultaneous to the
commission of the offense with which he is charged.
Since the state of a person's mind can only be judged by his behavior, establishing the insanity of an
accused requires opinion testimony which may be given by a witness who is intimately acquainted
DEAN’S CIRCLE 2019 – UST FCL
28
with the accused, or who has rational basis to conclude that the accused was insane based on the
witness' own perception of the accused, or who is qualified as an expert, such as a psychiatrist.
Taken against the standard of clear and convincing evidence, the proof proffered by the defense
fails to pass muster. Imelda and Mercy testified that accused-appellant believed that the victim was
a witch and that in the days prior to the incident, accused-appellant was behaving oddly, such as
smiling to himself and calling a chicken late at night. Their testimonies, however, fail to shed light
on accused-appellant's mental condition immediately before, during, and immediately after he
committed the crime. Moreover, those mentioned unusual behaviors are not proof of a complete
absence of intelligence, because not every aberration of the mind or mental deficiency constitutes
insanity.
In addition, Dr. Escuadera testified she conducted a psychiatric interview with accused-appellant
on 21 July 2009, and that her findings, showed she deemed accused-appellant fit for trial; and that
accused appellant had a history of mental illness, which she identified as schizophrenia.More
importantly, Dr. Escuadera's testimony on accused-appellant's previous mental illness does not
specifically pertain to the time of the commission of the crime. Even her medical report on accused-
appellant's mental status, for the purpose of determining his fitness to stand trial, is bereft of any
indication that he was completely deprived of intelligence or discernment at the time he mortally
hacked the victim.
Vague references to his history of mental illness and subsequent diagnosis of schizophrenia do not
satisfy the quantum of proof required to exempt accused-appellant from criminal liability,
especially since the defense failed to establish that accused-appellant's mental ailments, if such was
the case, related to the time of the commission of the crime.
Accused-appellant's actuations immediately after the incident also negate a complete absence of
intelligence or discernment when he killed the victim. As testified to by PO3 Corono, accused-
appellant approached the police officers when they arrived at the crime scene, told them that he
was responsible for hacking the victim, pointed to the bolo he used, and indicated that he had
already washed the weapon.The foresight to wash the bolo after killing the victim and, thereafter,
the consciousness to decide to confess to the authorities what he had done upon their arrival,
suggest that accused-appellant was capable of discernment during the time of the incident.
From the foregoing, it is clear that the defense failed to prove the accused-appellant’s insanity hence his
conviction must be upheld.
