Case Digest (G.R. No. 233193)
Facts:
On May 14, 2008 in Carigara, Leyte, Renato Bacolot y Idlisan, armed with a scythe, hacked Rodolfo Leona Jabayjabay three times while Rodolfo was singing with his face turned toward a television, and then also hacked Arnulfo Jabayjabay; Rodolfo died from hypovolemic shock due to blood loss from the hacking wounds, with the neck injury being fatal. Renato was later charged with murder; on arraignment, he invoked insanity, prompting psychiatric examination and suspension of trial, followed by a finding that he had regained competency and his subsequent plea of not guilty.The RTC convicted Renato of murder, giving weight to eyewitness identification and finding that the insanity defense was not proven. The CA affirmed the conviction (with modification of exemplary damages), leading Renato to appeal.
Issues:
- Whether the CA erred in convicting Renato despite the alleged successful proof of insanity.
- Whether the CA erred in convicting Renato of murder despite the alleged failure t
Case Digest (G.R. No. 233193)
Facts:
- Background and filing of charges
- On June 12, 2008, an Information was filed charging Renato Bacolot y Idlisan (Renato or accused-appellant) with the crime of murder under Article 248 of the Revised Penal Code (RPC).
- The Information alleged that on or about May 14, 2008 in the Municipality of Carigara, Province of Leyte, Renato, armed with a bladed weapon and with evident intent to kill, with treachery, evident premeditation, and employing means to insure and afford impunity, attacked and hacked Rodolfo Leona Jabayjabay (Rodolfo), resulting in Rodolfo’s untimely death.
- Arraignment and mental evaluation proceedings
- At arraignment, Renato’s counsel manifested that Renato was suffering from mental disorder and requested examination at the Eastern Visayas Regional Medical Center (EVRMC), Psychiatric Department, Tacloban City, which the Regional Trial Court (RTC) granted.
- The medical report of Dr. Lorelei Grace C. Genotiva (Dr. Genotiva) from EVRMC affirmed that Renato was mentally incompetent to stand trial.
- Trial was suspended; Renato was sent to the National Center for Mental Health, Mandaluyong City, for further evaluation and treatment.
- On February 18, 2009, the RTC received a letter from Dr. Edison C. Galindez, Chief of the Forensic Psychiatry Section of the National Center for Mental Health, attesting that Renato had regained competency to stand trial and recommending his discharge.
- On May 20, 2009, Renato was arraigned and pleaded not guilty.
- Prosecution evidence
- The prosecution presented Arnulfo Jabayjabay (Arnulfo) (brother of Rodolfo), Dr. Bella Profetana (Dr. Profetana) (post-mortem examiner), and Angeles (mother of Rodolfo and Arnulfo).
- Arnulfo testified that on May 14, 2008, while he, Renato, and other companions had a drinking spree, Rodolfo joined them.
- Arnulfo testified that Renato suddenly took a scythe (matabia) from Arnulfo’s waist and hacked Rodolfo three times, hitting the neck, back, and fingers.
- Arnulfo testified that Rodolfo was singing with his face turned toward the television when the hacking occurred.
- Arnulfo testified that Renato then turned toward Arnulfo and hacked him on the neck, head, and left shoulder.
- Arnulfo testified that Arnulfo survived, while Rodolfo died.
- Dr. Profetana testified on the post-mortem examination and opined that Rodolfo’s death was hypovolemic shock secondary to blood loss due to hacking wounds.
- Dr. Profetana identified four wounds: (1) right side of the neck; (2) back; (3) an incised wound on the arm; and (4) an incised wound on the right hand.
- Dr. Profetana opined that the neck injury was fatal.
- Dr. Profetana opined that the hacking wound on the neck might have been inflicted when the victim was in a position lower than the assailant.
- Angeles testified that she passed by the lifeless body of Rodolfo lying at the side of the road in Brgy. Sta. Fe, Carigara, Leyte.
- Angeles testified that she informed Barangay Kagawad Emeriata Dacara, who reported via text message to police authorities.
- Defense evidence and plea of insanity
- Renato pleaded insanity as defense.
- Renato’s lone witness was Dr. Genotiva.
- Dr. Genotiva testified that she examined Renato in 2005 prior to his arrest.
- Dr. Genotiva testified that Renato attempted to burn himself and had suicidal tendencies.
- Dr. Genotiva diagnosed Renato in 2005 as having auditory hallucinations and depressed mood with appropriate effect, and being able to converse but not oriented to time and place, with poor memory recall and blank stares.
- Dr. Genotiva testified that after Renato’s arrest (August 15, 2008; September 12, 2008; October 10, 2008), she observed persistent psychotic tendencies despite calm behavior.
- Dr. Genotiva testified that she recommended against Renato’s trial because he still had psychotic trends.
- Dr. Genotiva testified that Renato had poor memory recall of incidents relating to the commission of the crime and that he did not know what he did at the time.
- Dr. Genotiva testified that Renato showed not only psychotic trends but a full-blown psychosis and that his schizophrenia had no chance of being completely healed.
- Ruling of the RTC (murder conviction)
- After trial, the RTC convicted Renato of murder on September 22, 2014.
- The RTC gave credence to Arnulfo’s positive identification of Renato as the assailant.
- The RTC found that the testimonies of other witnesses and documentary evidence corroborated Arnulfo’s identification. ...(Subscriber-Only)
Issues:
- Criminal responsibility and plea of insanity
- Whether the CA gravely erred in convicting Renato despite the defense’s alleged proof of insanity immediately prior to, during, and immediately after the hacking of Rodolfo.
- Whether Renato’s act should be exempted from criminal liability under the plea that he was completely deprived of intelligence, making the criminal act involuntary.
- Criminal characterization: treachery and evident premeditation
- Whether the CA gravely erred in convicting Renato of murde...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)