G.R. No. 130487 - People vs. Estrada

On December 29, 1994, Roberto Estrada y Lopez was charged with murder under Article 248 of the Revised Penal Code for fatally stabbing security guard Rogelio P. Mararac “with treachery and committed in a holy place of worship.”
At the January 6, 1995 arraignment, defense counsel moved to suspend arraignment and commit the accused for psychiatric examination based on a claimed mental defect and prior confinement at Baguio General Hospital. The trial court, after propounding questions to the accused and finding his answers “intelligent,” denied the motion and entered a not guilty plea on his behalf.

The prosecution presented Dr. Tomas Cornel (autopsy and death certificate), eyewitness Crisanto Santillan, SPO1 Conrado Francisco (arresting officer), and Rosalinda Sobremonte (victim’s sister). They testified that during a confirmation rite at St. John’s Cathedral, the accused sat in the Bishop’s chair, refused to move, and then stabbed Mararac below the left throat and on the left arm.
Mararac died shortly after arrival at the hospital from cardiorespiratory arrest due to massive intrathoracic hemorrhage. The accused was disarmed, wrestled with a Deputy Police Chief, subdued, and taken into custody. Autopsy revealed two penetrating stab wounds with severe pulmonary vessel laceration.

After the prosecution rested, the defense filed a demurrer to evidence asserting lack of treachery, presence of unlawful aggression, and that the accused was of unsound mind; the trial court denied the demurrer.
Subsequent motions (February 1996) for psychiatric confinement and examination—supported by letters from jail wardens and fellow inmates detailing erratic behavior—were ignored. At trial the defense finally presented Dr. Maria Soledad Gawidan and clinical records showing a 1993 diagnosis of chronic paranoid schizophrenia and prior hospitalization.

On June 23, 1997, the Regional Trial Court, Branch 44, Dagupan City found the accused guilty of murder with the aggravating circumstance of cruelty, imposed the death penalty, and awarded civil indemnities and damages.
The accused appealed, assigning errors: (a) conviction despite clear and convincing proof of insanity; and (b) improper qualification of murder by treachery and cruelty.

Whether the trial court erred in convicting the accused despite evidence supporting the insanity plea.
Whether the trial court erred in finding the killing was attended by treachery and aggravated by cruelty.