Title
People vs. Austria y Navarro
Case
G.R. No. 111517-19
Decision Date
Jul 31, 1996
Accused, diagnosed with schizophrenia, acquitted of murder and frustrated murder due to insanity; ordered confinement and civil liability for victims' heirs.
A

Case Digest (G.R. No. 111517-19)

Facts:

  • Parties and informations filed
    • THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, filed three informations with the Regional Trial Court of Lingayen, Pangasinan, dated November 20, 1989, charging ROGER AUSTRIA Y NAVARRO ALIAS "BERNIE", ACCUSED-APPELLANT with two counts of murder and one count of frustrated murder, invoking Art. 248 and Art. 6 of the Revised Penal Code as appropriate.
  • Particulars of the three informations and injuries alleged
    • Information charging Frustrated Murder of Mylene Samson: stab wounds to mid-epigastric and left hypochondriac areas penetrating liver and lacerating pancreas; prosecution alleged appellant performed all acts of execution of murder but death was prevented by timely medical assistance.
    • Information charging Murder of Myrna C. Samson: multiple stab and incised wounds to neck, shoulder, chest (nine stab wounds), abdomen, and extremities; prosecution alleged these injuries caused her death.
    • Information charging Murder of Tyrone Samson: multiple stab wounds to chest, back (seventeen stab wounds), upper and lower extremities, and penetrating wounds to right and left lungs; prosecution alleged these injuries directly caused his death.
  • Pretrial pleas and trial court conviction
    • ROGER AUSTRIA Y NAVARRO pleaded not guilty to each charge; the three cases were tried jointly.
    • On June 14, 1993, the trial court convicted him on two counts of Murder and one count of Frustrated Murder, sentencing him to double reclusion perpetua for the two murders and to four years and six months of prision correccional to sixteen years and six months of prision mayor for the frustrated murder.
    • The trial court ordered indemnities of P50,000.00 to the heirs of Myrna, P50,000.00 to the heirs of Tyrone, and P40,000.00 to Mylene, and imposed costs.
  • Prosecution's factual narrative at trial
    • On September 25, 1989, between midnight and one o'clock a.m., Myrna and six of her seven children were asleep in their house at Barangay Domalandan, Lingayen; ROGER AUSTRIA Y NAVARRO, their next-door neighbor, allegedly entered the house without consent and proceeded to the room where Myrna and two sons slept.
    • The prosecution alleged appellant stabbed Myrna and Tyrone repeatedly with a "balisong"; Myrna fell dead by the stairs and Tyrone died in front of an altar; Mylene, age twelve, awoke, peeped through a door opening, was seen by appellant and stabbed several times but survived.
    • Guadalupe dela Cruz, Myrna's mother, rushed to the scene, saw the bodies, observed appellant running away with a "balisong," and procured police assistance; Mylene was transported to Pangasinan General Hospital for treatment.
    • Dr. Noel Manaois examined Mylene and found two deep stab wounds that could have been fatal but for timely medical attention; Dr. Jose S. Rosario performed autopsies on Myrna and Tyrone and prepared autopsy reports describing the fatal injuries.
    • Appellant denied killing Myrna and Tyrone and denied attempting to kill Mylene.
  • Defense evidence and psychiatric evaluation
    • Appellant presented psychiatrist Dr. Constantine D. Della, who examined and treated him and issued a Psychiatric Evaluation dated November 14, 1991 diagnosing ...(Subscriber-Only)

Issues:

  • Issues raised on appeal
    • Whether the trial court erred in not giving probative weight to the psychiatric evaluation and testimony of Dr. Constantine D. Della finding ROGER AUSTRIA Y NAVARRO to be suffering from long-standing Schizophrenic Psychosis, Paranoid type, thereby rendering him legally insane at the time of the offenses.
    • Whether the trial court erred in appreciating the aggravating circumstances of...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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