Case Digest (G.R. No. 209527)
Facts:
This case involves the accused-appellant Wilson Cacho y Songco who was charged with the crimes of Murder and Destructive Arson arising from incidents that took place on or about January 1, 2004, in the Municipality of Rodriguez, Province of Rizal. In Criminal Case No. 7522, Cacho was charged with Murder for allegedly attacking, assaulting, and beheading Mario Balbao y Adami, with qualifying circumstances of treachery, evident premeditation, and nighttime. In Criminal Case No. 7523, he was charged with Destructive Arson for willfully burning the victim’s house to conceal evidence of the murder, with the aggravating circumstance of spite or hatred.
Upon arraignment, Cacho pleaded not guilty but raised the defense of insanity, claiming a history of mental illness treated at the National Center for Mental Health (NCMH), including diagnoses of Major Depression with Psychosis and later Chronic Schizophrenia. Police officers arrived at the scene following a fire report and found the v
Case Digest (G.R. No. 209527)
Facts:
- Charges and background
- Wilson Cacho y Songco (accused-appellant) was charged with Murder (Criminal Case No. 7522) and Destructive Arson (Criminal Case No. 7523) committed on or about January 1, 2004, in Rodriguez, Rizal.
- Murder charge: Accused, armed with a bladed weapon, willfully, unlawfully, and feloniously attacked and beheaded Mario Balbao y Adami with qualifying circumstances of treachery, evident premeditation, and nighttime.
- Destructive Arson charge: Accused willfully and feloniously set fire to and burned the victim’s house to conceal evidence of the crime of murder, motivated by spite or hatred.
- Investigation and arrest
- On January 2, 2004, police and Bureau of Fire Protection personnel responded to a report of fire in Sitio Catmon, Brgy. San Rafael, Rodriguez, Rizal.
- Investigators found the burned house of Mario Balbao and the burned, headless body of a man underneath an iron sheet.
- Willy Cacho informed police that his brother, the accused-appellant, killed Mario. Accused-appellant’s wife said he suffered recurring mental illness and was a patient at the National Center for Mental Health (NCMH).
- Police discovered in accused-appellant’s backyard a shallow pit with a steel peg, ashes, and a human skull, believed used to burn a head.
- Upon confronting accused in his backyard, he acted strangely, admitted killing Mario and burning the house but refused to state the motive; he resisted arrest and was subdued and taken into custody.
- Accused-appellant was brought for inquest and later confined at the NCMH.
- Trial and rulings below
- Accused pleaded not guilty; trial ensued focusing on the issue of insanity due to accused’s admission of the acts.
- The Regional Trial Court (RTC) convicted accused of Murder and Destructive Arson and sentenced him to reclusion perpetua on both counts, awarding damages to the victim’s heirs.
- The Court of Appeals (CA) affirmed the RTC Decision.
- Accused appealed to the Supreme Court, raising the sufficiency of evidence on the defense of insanity and the crimes charged.
Issues:
- Whether the accused-appellant sufficiently proved his defense of insanity.
- Whether the crimes of Murder and Destructive Arson were sufficiently established beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)