G.R. No. 223114 - People vs. Pantoja y Astorga

Accused-appellant Jonas Pantoja y Astorga was charged with the crime of murder for fatally stabbing a six-year-old child (identified as AAA) on July 22, 2010 in the City of Taguig.
The stabbing, committed with a bladed weapon (kitchen knife), was alleged to have been done with treachery and in a manner that exploited the victim’s vulnerability as a child, thereby constituting an act of cruelty.

On the morning of July 22, 2010, while the accused-appellant and his mother, Cederina, were at their residence, it was observed that the accused-appellant had left the premises.
Cederina later discovered that the front door of a neighboring house (where the child victim resided) was open, heard the cry of a child, and upon investigating upstairs, found the accused-appellant holding a knife with the victim already sprawled bloodied on the floor.

Cederina detailed the accused-appellant’s history of mental illness, noting that he had been confined in psychiatric facilities (NCMH and PGH) and had exhibited odd or erratic behavior prior to the incident.
She testified about his escape from confinement on July 14, 2010, and his behavior thereafter, including a pattern of repeatedly going in and out of the house.
Provided an account of the events on the day of the crime, describing her discovery of the scene and actions taken immediately afterward.

Conducted an autopsy on the victim which revealed four stab wounds – on the forehead, neck, right shoulder, and below the collar bone.
His findings substantiated the fatal nature of the injuries inflicted by the accused.

Offered details on the funeral arrangements and incurred expenses, evidencing the tangible damage suffered by the victim’s family.

A letter from the National Center for Mental Health (NCMH) regarding the accused-appellant’s escape.
Patient identification cards from both the NCMH and PGH.
The accused-appellant’s clinical records and doctor’s prescriptions.

The accused-appellant admitted to having a history of mental illness dating back to 2003, which led to intermittent confinements and treatment on orders of doctors.
He testified that he had been receiving medication continuously, though occasionally interrupting the regimen when he felt well.
His defense centered on claiming that he could not precisely recall the events on the morning of July 22, 2010, thereby raising the possibility of insanity or diminished capacity during the commission of the crime.
The defense also argued that his longstanding mental illness diminished his exercise of willpower, which could serve as a mitigating circumstance in sentencing.

The Regional Trial Court (RTC) found the accused-appellant guilty beyond reasonable doubt of murder, sentencing him to reclusion perpetua and ordering payment of actual, civil indemnity, and moral damages to the victim’s heirs.
On appeal, the Court of Appeals (CA) affirmed the RTC’s conviction with modification, particularly in the award of damages, while reiterating that the evidence did not support a conclusive finding of insanity at the time of the crime.

The testimonies, especially that of Cederina, described intermittent abnormal behavior of the accused in the days preceding the incident; however, no behavior during or immediately prior to the stabbing was conclusively indicative of a complete loss of reason or free will.
Documentary evidence such as clinical abstracts and admission records confirmed his mental health history but failed to demonstrate continuous or complete mental incapacity at the time of the offense.

Whether the accused-appellant has clearly and convincingly proven his defense of insanity to exempt him from criminal liability.

Analysis of whether the evidence presented meets the strict legal requirements for an insanity defense, which demands establishing a complete deprivation of intelligence, reason, or discernment.

Whether the accused-appellant’s history of mental illness and the observed diminished willpower should serve as a mitigating circumstance to lower the penalty imposed.

Consideration of the legal principle that even if diminished capacity is shown, it does not alter the nature of the crime nor necessarily reduce the imposition of reclusion perpetua due to its indivisible character.