Case Digest (G.R. No. 108405)
Facts:
People of the Philippines v. Randy Belonio y Landas, G.R. No. 148695, May 27, 2004, the Supreme Court En Banc, Per Curiam.The accused-appellant is Randy Belonio y Landas; the prosecution is the People of the Philippines. An Amended Information dated April 27, 2000 charged Belonio with Murder for the stabbing death of Ramy (Ramon) Tamayo on January 6, 2000 in Talisay City, Negros Occidental, alleging the use of an improvised knife with treachery and evident premeditation; the Information also alleged recidivism based on a prior final conviction for homicide (Crim. Case No. 94-16609). Belonio was arraigned May 24, 2000 and pleaded not guilty.
At trial the principal eyewitness, Jennifer Carampatana, testified that during a wake she and the victim were sitting on a bench near a neighborhood store when Belonio approached, conversed briefly, left, returned wearing long sleeves, then without warning stabbed Tamayo in the chest; Tamayo was incapacitated and died from a wound penetrating the heart as established by Dr. Raul V. Pama, Jr.'s necropsy. Belonio was arrested shortly after fleeing and hiding in a nearby house. The trial court (RTC, Negros Occidental, Branch 50, Bacolod City) found these facts proven and convicted Belonio of Murder on February 26, 2001, sentencing him to death and awarding civil indemnity (P50,000), hospital reimbursement (P3,629.70), compensatory damages (P940,716.00), and moral damages (P100,000).
Before the RTC Belonio raised insanity as an exempting circumstance under Article 12, relying chiefly on the testimony and a medical certificate of private psychiatrist Dr. Antonio Gauzon, who diagnosed chronic undifferentiated schizophrenia possibly triggered by substance abuse. The prosecution presented Dr. Ester Regina Servando, who conducted a two-day psychiatric evaluation with written tests and concluded Belonio exhibited evasive, suspicious and manipulative behavior but displayed no psychotic features at the time of examination. The RTC credited Dr. Servando over Dr. Gauzon and found Belonio retained full control of his mental faculties.
Because the penalty imposed was death, the case came to the Supreme Court by automatic review. In this Court the appellant argued the trial court erred in rejecting insanity; the Solicitor Ge...(Subscriber-Only)
Issues:
- Did the trial court err in rejecting the defense of insanity and in finding that the accused was criminally responsible at the time of the killing?
- Were the penalty imposed and the civil damages awarded by the trial court proper, and should ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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