G.R. No. 87084 - People vs. Aquino

Appellant Juanito Q. Aquino was charged with the crime of rape with homicide committed on or about February 13, 1987.
The offense occurred in Barangay Poblacion in Pangasinan, where the victim, Carmelita Morado (alias Carmen), 18 years old, was reportedly raped and struck with a stone.

On the night of February 13, 1987, victim Carmelita Morado was found in the clinic of Dr. Padlan with head bleeding, evidencing assault and physical injuries.
The victim’s statement, taken by police officer Armando Frias—with corroboration from other officers and the attending physician—detailed that appellant used force and intimidation to commit the act, which included a violent blow that ultimately led to her death the following morning.

Appellant was arrested the same evening at the town auditorium during a Valentine dance by police officers, and later transferred to the municipal jail in Urbiztondo, Pangasinan.
A motion by appellant’s counsel on June 26, 1987, requested the indefinite suspension of the trial and the commitment of the accused to the National Center for Mental Health due to alleged unstable behavior.
The trial court granted the motion on July 1, 1987, placing the proceedings in abeyance until the completion of the mental evaluation and subsequent arraignment on April 27, 1988.

Appellant’s defense centered on his claim of insanity at the time of the crime, supported by:

A clinical case report from the National Center for Mental Health detailing his mental and physical condition.
Testimony of Dr. Nicanor L. Echavez, who diagnosed appellant with an organic mental disorder with psychosis and asserted that he was deprived of reason when committing the crime.

Testimony from appellant’s father regarding a long history of abnormal behavior and prior confinement for wandering naked in 1985.
Observations by police personnel (including Sgt. Raymundo Lomboy and other members) noting appellant's abnormal behavior and episodes while in custody.
Appellant’s own extrajudicial confession, which admitted not only involvement in the crime but also the consumption of substances (cough syrup and marijuana) prior to the offense.

The prosecution presented multiple witnesses who testified that appellant was lucid and acted normally both before and after the incident:

Armando Frias testified that appellant gave responsive answers during the investigation, having known him from previous encounters on the construction site.
Angel Baysic and Carlos Sabangon testified to his normal behavior based on personal acquaintance with the accused.
Eduardo Fernandez, a jail guard, remarked on the absence of any abnormal behavior during imprisonment.

The extrajudicial confession of appellant was executed with the assistance of Atty. Liliosa Rosario from the Citizens Legal Assistance Office (CLAO).
During the investigation and subsequent arraignment, appellant was advised of his constitutional rights, and his statement was read, translated, and duly signed in the presence of a judge and counsel.

After trial on the merits, the trial court found appellant guilty of rape with homicide.
Although the defense raised issues concerning his mental incapacity and the admissibility of his extrajudicial confession, the trial court was not persuaded that the evidence of insanity was sufficient to overcome the presumption of sanity.
The trial court imposed a penalty of life imprisonment along with a civil indemnity award, later adjusted to reclusion perpetua and a reduction of indemnity to P30,000.00 by the appellate court.

Whether appellant, having invoked the defense of insanity, was able to overcome the presumption of sanity with sufficient and clear evidence.

Does the clinical case report and the testimony of Dr. Nicanor L. Echavez establish that appellant was insane at the time of the commission of the crime?
Is the evidence offered regarding his mental condition too nebulous and conjectural to exonerate him or extenuate his criminal liability?

Whether the extrajudicial confession—executed with the assistance of counsel and explained properly in his dialect—was admissible.
Whether any defect in the procedure of securing the confession could have affected its reliability and consequently the verdict.

Whether the proper nomenclature of the penalty should be reclusion perpetua instead of life imprisonment, as prescribed by the Revised Penal Code.
The appropriate quantum of civil indemnity against the victim’s heirs in light of prevailing jurisprudence.