Title
People vs. Pana y Idan
Case
G.R. No. 214444
Decision Date
Nov 17, 2020
Lito PaAa convicted of murder; insanity defense rejected due to lack of medical evidence, despite claims of mental illness. Damages increased.

Case Digest (G.R. No. 214444)
Expanded Legal Reasoning Model

Facts:

  • Criminal incident
    • On March 20, 2005 at around 7:30 a.m. in Barangay Masaya, Rosario, Batangas, Lito PaAa y Inandan (PaAa) armed with a bolo attacked and hacked his sleeping cousin, Sherwin Macatangay y Lara, inflicting fatal incised wounds on the head and neck.
    • Witness Aldwin Andal fled and reported the incident; police found PaAa 25–30 meters away, lying on the ground with the bolo, attempted flight, and was apprehended.
  • Trial and defense
    • The Regional Trial Court (RTC) convicted PaAa of murder, sentencing him to reclusion perpetua and ordering ₱50,000 death indemnity to the heirs.
    • PaAa interposed the defense of insanity, testifying he suffered depression, sleepless nights, and attempted suicide since 2003; his mother corroborated unusual behavior and blank stares, but they presented no medical expert.
    • The Court of Appeals affirmed the conviction, holding PaAa failed to prove complete deprivation of intelligence at the time of the crime and that lay testimony alone was insufficient. PaAa appealed to the Supreme Court.

Issues:

  • Whether PaAa’s defense of insanity exempts him from criminal liability for murder under Article 12(1) of the Revised Penal Code.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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