Title
Supreme Court
People vs. Haloc y Codon
Case
G.R. No. 227312
Decision Date
Sep 5, 2018
Accused with mental illness history convicted of murder and attempted murder after attacking two children; insanity defense rejected, civil liabilities modified.

Case Digest (G.R. No. 227312)
Expanded Legal Reasoning Model

Facts:

  • Incident and Apprehension
    • On June 22, 2008, at around 12 noon, accused-appellant Jessie Haloc y Codon, then 51 years old, was apprehended by barangay officials after hacking Allan de la Cruz (9 years old) and his brother Arnel de la Cruz (4 years old) inside the de la Cruz’s yard in Barangay Union, Gubat, Sorsogon.
    • Arnel died immediately due to a severe neck wound; Allan sustained injuries to his upper arm but survived after medical treatment.
  • Circumstances of the Attack
    • The accused, armed with a 24-inch bolo, initially attempted to strike the victims’ father, Ambrosio de la Cruz, who escaped.
    • The five sons of Ambrosio followed him, leading Jessie to target the children instead. He hacked Allan’s right arm and inflicted mortal wounds on Arnel’s neck, severing the jugular veins.
  • Charges Filed
    • Criminal Case No. 2780 charged accused with Attempted Murder of Allan de la Cruz, alleging treachery and advantage of superior strength, armed with a bolo, intending to kill, but failing to accomplish murder due to Allan’s medical assistance.
    • Criminal Case No. 2781 charged accused with Murder of Arnel de la Cruz under similar circumstances.
  • Mental Condition and Proceedings
    • On the scheduled arraignment date, the Public Attorney’s Office (PAO) manifested the accused’s apparent mental unfitness to be interviewed and requested psychiatric evaluation, which the court granted.
    • Psychiatric evaluation by the Department of Psychiatry of Bicol Medical Center on July 7, 2010, declared the accused fit for trial.
    • The accused pleaded “not guilty” to both charges during arraignment.
  • Defense of Insanity and Witness Testimony
    • The defense invoked insanity and proceeded to present evidence first.
    • Araceli Haloc-Ayo, accused’s sister, testified that the accused had become angry due to noise disturbance and lack of sleep, acted fiercely during the attack, but recognized her and surrendered the bolo afterwards. She attested he was acting differently but did not witness the attack.
    • Susan Haloc, the accused’s wife, testified on his 30-year marriage and past mental disorder episodes:
      • Treated for mental disorder in 2003 and was well after medication.
      • Relapse in 2008 due to alcohol drinking; prescribed medicine by Dr. Gregorio.
      • Accused showed glazed eyes, impaired work capacity, failure to recognize family members shortly before incident, causing her to leave two days prior.
    • Dr. Imelda Escuadra, psychiatrist, confirmed accused’s admission and treatment at Don Susano Memorial Mental Hospital on multiple occasions (2003, 2007, and late 2008), but was not the attending physician and did not categorically diagnose psychosis.
  • Trial Court Ruling and Appeal
    • The RTC rejected the insanity defense, ruling no total deprivation of reason or intelligence was established. It convicted accused of Attempted Murder and Murder.
    • The RTC imposed indeterminate sentence for Attempted Murder and reclusion perpetua for Murder, with civil indemnity and moral damages awarded to victims and heirs.
    • On appeal, the CA affirmed the convictions with modifications: deleted P5,000 medical expenses award to Allan, imposed 6% per annum interest on indemnities and moral damages from finality until full payment.
    • Both parties waived filing supplemental briefs in this appeal.

Issues:

  • Whether the defense of insanity should be appreciated as exempting the accused from criminal responsibility.
  • Whether the accused’s mental condition qualifies as a mitigating circumstance in the commission of the crimes.
  • Whether the awards for damages should be modified.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.