G.R. No. 158791 - Civil Service Commission vs. Department of Budget and Management

Fernan Calines y Magastino (Calines) was charged with two crimes in separate informations: frustrated homicide (Criminal Case No. 16-CR-11674) involving victim Nida Calasiao Sabado, and murder (Criminal Case No. 17-CR-11741) involving victim Sky Sabado y Calasiao, a three-year-old child.
Both incidents took place on December 19, 2016, at Sitio Pasanan, Ambassador, Municipality of Tublay, Benguet.
The frustrated homicide charge alleged that Calines struck Nida several times with a piece of wood intending to kill her, but she survived due to her escape and timely medical intervention.
The murder charge alleged that Calines, with intent to kill and employing treachery and superior strength, fatally struck Sky multiple times with a piece of wood.

During arraignment on March 13, 2017, Calines initially intended to plead guilty but sought cancellation to understand plea consequences.
On March 28, 2017, Calines pleaded guilty in Ilocano, followed by trial on the merits.

Witnesses for the prosecution included Nida (the victim), Dr. Paolo Angelo R. Igama (attending physician), and Tyler Tudayan (community member).
Nida testified that she and her son Sky were attacked by Calines, who struck her repeatedly and forcibly dragged her son outside their shanty.
Tyler recognized Calines by description and personal acquaintance, later aiding in informing neighbors.
Sky was found near the shanty and rushed to hospital, dying four days later; death and medical certificates confirmed cause as traumatic brain injury due to mauling.
Nida suffered injuries but was immediately discharged, with no medical testimony or receipts presented on the injury's severity or medical expenses.

Defense initially waived evidence but later moved to reevaluate plea, claiming Calines suffered unspecified psychosis.
Psychiatrist Dr. Donnalyn G. Gamueda examined Calines thrice in 2018, diagnosed schizophrenia paranoid type; however, Calines was oriented and could not narrate the crime details.
Calines’s sister Gloria testified to past psychiatric hospitalization (2014–2016) and discontinuation of medication in 2016.

Frustrated homicide (sentenced to 4 years and 1 day to 8 years and 1 day imprisonment) with damages awarded to Nida.
Murder (sentenced to reclusion perpetua) with damages awarded to Sky’s heirs.

RTC ruled Calines failed to prove insanity by clear and convincing evidence, noting the absence of proof of mental state at the time of the crimes.
RTC found no corroboration for Dr. Gamueda's findings except Gloria's testimony about prior psychiatric history.

Calines found guilty of attempted homicide (not frustrated homicide) and sentenced to 6 months to 4 years and 2 months imprisonment, with reduced damages awarded to Nida.
Confirmed guilt for murder with reclusion perpetua and modified damages for Sky’s heirs.

CA discredited psychiatric evaluation as based on statements two years post-crime and hearsay.
Noted Calines’ initial guilty plea and late invocation of insanity defense diminished credibility of insanity claim.
Found treachery present in murder; abuse of superior strength absorbed by treachery.
Determined wounds on Nida were non-fatal and resolved doubts in favor of accused.

Parties were allowed to file supplemental briefs but both declined, considering prior briefs comprehensive.

Whether the Court of Appeals erred in affirming Calines’s conviction for murder and attempted homicide.
Whether Calines’s defense of insanity was sufficiently established to exempt him from criminal liability.
Appropriate penalties and damages to be imposed for the crimes.