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G.R. No. 244692-3-4

The document discusses the case of a petitioner diagnosed with psychotic disorders leading to the homicide of a close friend. Despite expert testimonies suggesting her insanity, the Regional Trial Court and Court of Appeals upheld her conviction for homicide, concluding that she was not insane at the time of the crime. The petitioner argues that her mental state was affected by dehydration and malnutrition, but the courts found insufficient evidence to support her claim of insanity during the incident.
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0% found this document useful (0 votes)
15 views2 pages

G.R. No. 244692-3-4

The document discusses the case of a petitioner diagnosed with psychotic disorders leading to the homicide of a close friend. Despite expert testimonies suggesting her insanity, the Regional Trial Court and Court of Appeals upheld her conviction for homicide, concluding that she was not insane at the time of the crime. The petitioner argues that her mental state was affected by dehydration and malnutrition, but the courts found insufficient evidence to support her claim of insanity during the incident.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd

suffering from "PSYCHOTIC Disorder due to a Medical Condition" by reason of her "Hyponatremia,

Decreased Electrolytes and Decreased Nutritional Status." In other words, Dr. Luspo determined that
[petitioner's] psychosis was due to dehydration and malnutrition.

On 28 June 2005, [petitioner] was admitted to the NCMH and was treated by Dr. Lazaro, who
discovered that five (5) (days] before the victim was killed, (petitioner] was not properly nourished (as
she and the victim had fasted), and was already hallucinating and hearing voices. Thus, Dr. Lazaro
concluded that [petitioner] was afflicted with "Schizophrenic, Paranoid type" and testified that she was
insane before, during[,] and after the commission of the crime. As a matter of fact, after having been
discharged from the NCMH, she continued her treatment or medication at the outpatient section thereof
from 10 August 2005 until 10 June 2008.12

On the other hand, the prosecution presented three witnesses, namely: (1) Police Chief Inspector Jose Arnel M.
Marquez, the medico-legal officer who conducted an autopsy on the victim; (2) Reverend Father Jericho M. Natividad
(Fr. Natividad), a close friend of the victim and who also knew petitioner; and (3) Emily Bonifacio Madriaga, the
private complainant and the older sister of the victim.13

The prosecution's version of the incident was summarized in the CA Decision as follows:

[Petitioner] and the victim were close friends. They had been friends [ever] since [petitioner was] at
least 6th grade, [or] when [petitioner] was around 12 or 13 years old. [Petitioner] was also the victim's
former student at the Naval, Architecture, and Marine Engineering Institute Polytechnic Institute at
Mandaluyong City, and that the victim had treated [petitioner] like her own daughter. [Petitioner] was
known as a shy and quiet girl. Mr. Ruiz, the father of [petitioner], even asked the victim to move in with
[petitioner] free of charge because of how close they were to each other.

Then on 13 June 2005, as admitted at pre-trial, [petitioner] killed the victim.

According to Mr. Ruiz, someone came to his house at around 7:00 in the morning of 13 June 2015
to report that something was happening with [petitioner]. He then hurried to the victim's residence, about
one block from his house, to see what was happening. When Mr. Ruiz arrived, he was assisted by
another person in entering the room where his daughter was, because the door was locked.

Mr. Ruiz found his daughter naked on top of the corpse of the victim, who was already apparently
dead. [Petitioner] had stuck her hand and fingers inside the victim's mouth. According to Mr. Ruiz,
[petitioner] appeared to be praying, and that her eyes were glaring. She was on top of the victim's
corpse which was [lying] on the floor.

The authorities then arrived after Mr. Ruiz. [Petitioner's] father then requested SPO1 Eugenio to
handcuff [petitioner] because she was supposedly "nagwawala," shouting[,] and reciting religious words.
[Petitioner] was allegedly hysterical and "hindi siya makausap." [Petitioner] was uncooperative when Mr.
Ruiz tried to get her.

The medico-legal who examined the victim's corpse testified that the cause of the victim's death
were traumatic injuries to her head, and that her sternum and ribs were also fractured. The medico-legal
also testified that these injuries were probably caused by being in contact with a hard and blunt object.

[Petitioner] was initially brought and treated by Dr. Valles-Luspo at the VPMC, who diagnosed
[petitioner] with having a psychotic disorder. [Petitioner] was then transferred to the NCMH on 28 June
2005, under the case of Dr. Lazaro, who diagnosed the said [petitioner] as suffering from paranoid
schizophrenia.14

Ruling of the RTC

In a Decision dated June 2, 2016, the RTC found petitioner guilty beyond reasonable doubt of Homicide. The
dispositive portion reads:

WHEREFORE, the Court finds the accused guilty of Homicide and is therefore sentence [sic] to
a penalty of minimum of Reclusion Temporal or 12 years and 1 day to 14 years and 8 months and to
pay civil liability of a) [PHP]50,000.00 and [PHP]4,000.00 as attorney's fees and appearance fees,
respectively and b) to indemnify the heirs of the victim with [PHP]50,000.00 for the death of the
victim.
SO ORDERED.15

According to the RTC, the findings of the expert witnesses for the defense, although showing an inclination
towards petitioner's insanity, were based on opinion gathered from interviews of petitioner and the parents, and
"notably, they even differ in the form or kind of mental illness and, possibly the case thereof."16

The RTC ruled that "opinion as to the mental state must not only be extensive, meaning, that it exists before,
during and after the crime but believed must all foreclose the possibility that accused killed the victim
conscientiously."17

The RTC also went further by inferring that Mr. Ruiz's testimony established that "somebody" put a chain on the
handle of the makeshift door and that another person helped him open the door. Thus, the RTC concluded that such
scenario tends to establish that as the victim was already waylaid on the floor at the time, the person who could have
put the chain was no less than petitioner.18

Furthermore, the RTC deduced from the fact that since both petitioner and the victim were naked when they were
found, they were possibly in an amorous relationship.19 The RTC then correlated this inference with a testimony
romantically linking the victim with Fr. Natividad and made insinuations that this could have driven petitioner to
commit such crime.20

Taking these conjectures together, the RTC concluded that petitioner was not suffering from insanity at the time
of commission of the crime.21

In an Order dated December 9, 2016, the RTC granted petitioner's motion to use the same bail pending appeal.22

Ruling of the CA

On August 28, 2018, the CA upheld petitioner's conviction for Homicide with modification as to the monetary
awards. The dispositive portion of the CA Decision reads:

WHEREFORE, the instant appeal is DENIED. The Decision dated 2 June 2016 of the Regional
Trial Court of Mandaluyong City, Branch 208 in Criminal Case No. MC05-9486 is
hereby AFFIRMED with MODIFICATION in that Accused-Appellant Mare Claire Ruiz y Serrano
is ORDERED to PAY civil indemnity in the amount of [PHP]50,000.00 and moral damages in the
amount of [PHP]50,000.00 to the heirs of the victim Paulita Bonifacio y Sumintac. The Accused-
Appellant Mare Claire Ruiz y Serrano is also ORDERED to PAY interest on all damages awarded at
the legal rate of six percent (6%) per annum from the date of finality of this Decision until fully paid.
All other aspects of the Decision STAND.

SO ORDERED.23

The CA primarily anchored its ruling on the fact that the examination, report, and testimonies of the expert
witnesses were all done after the commission of the crime. This, according to the CA, cannot be said to support the
(awÞhi(

conclusion that petitioner was insane at the time of the killing.24

In addition, the CA agreed with the RTC's inference that it was petitioner who placed the chains on the handles of
the makeshift door which prevented her father from initially entering the room.25 This, according to the CA, supports
the fact that petitioner was not deprived of intelligence at the time of the commission of the crime.26

Accordingly, the CA pronounced that petitioner failed to establish her insanity at the time she had killed the
victim.27

Hence, this Petition.

The Present Petition

Petitioner insists that she was able to prove her insanity with clear and convincing evidence. In the Petition, it
was highlighted that series of events and acts immediately preceding and succeeding the incident support her claim
that she did not possess the element of intelligence at the time of the commission of the crime. These included the
fact that they fasted for days, underwent non-stop praying, and the fact that petitioner was totally naked when they
were found by authorities without any weapons.28 Petitioner likewise emphasized that her expert witnesses testified
that she was suffering from Psychotic Disorder and Schizophrenia, paranoid type, and was thus, for legal intents and

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