G.R. No. 184343 - People vs. Domingo

This is a criminal case involving appellant Jesus Domingo, charged in six separate criminal cases (1496-M-2000 to 1501-M-2000) for offenses including murder, attempted murder, frustrated murder, and frustrated homicide.
The crimes occurred on or about 29 March 2000 in San Rafael, Bulacan, Philippines, when the accused allegedly attacked the Indon family while they were asleep inside their residence.

In Criminal Cases No. 1496-M-2000 and No. 1497-M-2000, the accused was charged with murder for fatally stabbing Marvin G. Indon and Melissa G. Indon, respectively, using a kitchen knife and a screwdriver; these acts were committed with evident premeditation, treachery, and taking advantage of superior strength.
In Criminal Case No. 1498-M-2000, the accused was charged with frustrated murder for attacking Michelle G. Indon, a minor of 9 years old, whose injuries were such that, under normal circumstances, they would have been fatal but for timely medical intervention.
In Criminal Case No. 1499-M-2000, the accused was similarly charged with frustrated murder for attacking Ronaldo Galvez, a neighbor who came to the assistance of the family, whereby his injuries likewise did not result in death due to immediate medical care.
In Criminal Case No. 1500-M-2000, the accused was charged with frustrated murder for attacking Raquel Gatpandan Indon, the mother of the victims, inflicting serious injuries that would have caused death but did not due to external factors.
In Criminal Case No. 1501-M-2000, the accused was charged with attempted murder for severely assaulting Jeffer G. Indon, a two-year-old boy, with a kettle, causing injuries that would have been fatal without timely intervention.

On the night of 29 March 2000, Raquel Indon and her minor children were asleep when the accused forcefully entered their home.
Testimonies by Raquel Indon described the assailant’s entrance, identification of the accused (locally known as “Doser”) via the illumination from the kitchen light, and the ensuing violent attack including stabbing her, her children, and attacking a neighbor.
Witnesses including Michelle Indon, a five-year-old Jeffer Indon, and the neighbor Ronaldo Galvez corroborated portions of Raquel’s account, with medico-legal reports and photographic exhibits supporting the occurrence and extent of the violent injuries.
Documentary evidence included sketches of the crime scene, death and medico-legal certificates, photographic exhibits, sworn statements, and statements of account for alleged expenses incurred (casket, burial, and hospitalization) by the victim’s family.
The prosecution’s evidence relied heavily on corroborated eyewitness testimonies, physical evidence (weapons, injury reports), and documentary proofs.
The defense presented an insanity plea, supported by the accused’s testimony and a later psychiatric evaluation (conducted in 2004) which diagnosed him with schizophrenia. However, the defense relied largely on events and symptoms reported days before the incident, without corroborative testimony from family or friends regarding his mental state at the time.

The RTC of Malolos, Bulacan, initially found the accused guilty beyond reasonable doubt in several criminal cases, convicting him for homicide and frustrated homicide, and awarding various penalties and monetary indemnities based on the victim’s losses.
The trial court rejected the defense’s insanity plea, reasoning that the evidence of mental disorder was from a time interval significantly after the commission of the crimes and that the accused’s actions (including his response to the plea of his victim) demonstrated awareness and intent.
On appeal, the Court of Appeals modified several aspects of the RTC decision, notably altering the qualification of circumstances such as treachery and premeditation and adjusting the penalties as well as the award of damages.
The appellate court affirmed the credibility of Raquel Indon’s testimony, noting that minor inconsistencies did not detract from the substantial evidence of a violent, unprovoked attack on a defenseless family.
The Court of Appeals further addressed the insanity plea, holding that mental disorder findings that postdate the commission of the crime do not exculpate criminal liability and that the accused’s actions during the incident evidenced sound mental faculties.

Whether the evidence, particularly the eyewitness testimonies, physical evidence, and documentary exhibits, was sufficient to sustain a finding of guilt beyond reasonable doubt for the crimes charged.
Whether the inconsistencies pointed out by the accused in the eyewitness accounts affect the determination of the essential elements of the offenses.

Whether the accused’s plea of insanity, which relied on his reported symptoms and later psychiatric evaluation, established that he was deprived of reason at the time of the commission of the crimes.
Whether the defense met the burden of proving, beyond reasonable doubt, that the accused was legally insane immediately before or at the very moment of the criminal acts.
The issue of whether the post-crime psychiatric evaluation diagnosing schizophrenia is relevant and sufficient to exempt him from criminal liability under Article 12 of the Revised Penal Code.

Whether the trial court and appellate court properly assessed and applied the appropriate penalties for murder, frustrated homicide, and attempted murder considering the proven aggravating circumstance of treachery.
Whether the awards for civil indemnity, moral, temperate, exemplary, and actual damages were properly supported by the evidence presented.