G.R. No. L-33211 - People vs. Puno y Filomeno

On September 8, 1970, at approximately 2:00 p.m., Ernesto Puno, a 28-year-old jeepney driver, entered the bedroom of Francisca Col (Aling Kikay), a 72-year-old widow, in her residence in Little Baguio, Barrio Tinajeros, Malabon, Rizal.
Upon seeing the victim, Puno insulted her by uttering phrases such as “Mangkukulam ka, mambabarang, mayroon kang bubuyog.”
He proceeded to physically assault her by slapping and striking her head with a hammer repeatedly until she was dead.
The assault was witnessed by Hilaria de la Cruz, 23, who was present in the bedroom, and Lina Pajes, 27, a tenant from an adjacent room.
After killing Aling Kikay, Puno issued threats to his witnesses, warning them against calling the police, and then fled to his parents’ house before later proceeding to the residence of his second cousin in Calumpit, Bulacan.

The crime scene was secured by the police. On arrival, Corporal Daniel B. Cruz discovered the victim’s body on the bed, with visible bloodstains and head injuries.
Witnesses Hilaria and Lina later identified Puno as the perpetrator based on his physical appearance, notably his reddish eyes and baleful expression.
A medico-legal officer performed an autopsy and confirmed that the victim suffered lacerated wounds on her right eyebrow, contusions on her head, and that the cause of death was intracranial traumatic hemorrhage.
Subsequent police actions included the surrender of Puno by his father and his transfer to the National Mental Hospital for examination.

Puno was charged with murder in the municipal court after waiving the second phase of the preliminary investigation.
On October 21, 1970, he was indicted in the Circuit Criminal Court at Pasig, Rizal, with the information alleging aggravating circumstances such as evident premeditation, abuse of superiority, and disregard of sex.
Despite his admission of memory loss regarding the killing, Puno’s testimony and behavior raised suspicions, compounded by his previously observed odd behaviors and recollections of supernatural phenomena.

Puno’s defense raised the exempting circumstance of insanity, supported by his eight-year psychiatric history of schizophrenia:

Records indicate initial treatment in 1962 for symptoms including laughing alone, peculiar gestures, and abnormal prayer habits.
His condition was marked by recurring episodes and partial remissions recorded in 1964 and 1966, with a final improvement or “remission” noted in July 1970.

Testimony from three psychiatrists (Dr. Araceli Maravilla, Dr. Reynaldo Robles, and Dr. Carlos Vicente) collectively revealed:

Puno had a diagnosed “schizophrenic reaction” and was known to have occasional psychotic symptoms.
At the time of the killing, his mental illness was not so incapacitating as to deprive him completely of reasoning or the capacity to distinguish right from wrong.
Puno’s residual symptoms did not amount to a state of complete legal insanity.

Episodes of erratic behavior prior to the killing, such as attacking his wife’s dog and expressing delusional beliefs about “mangkukulam” (witches or sorcerers).
Observations by family members and other witnesses noting Puno’s abnormal physical demeanor (reddish, bloodshot eyes, and ferocious demeanor).

The trial court noted that if Puno were truly a homicidal maniac, he would have attacked additional persons, not solely Aling Kikay.
The court observed Puno’s conduct during trial appearances, which corroborated his understanding of the proceedings.
The defense argued that chronic schizophrenia should exempt Puno from full criminal liability, citing his diminished will-power and residual psychotic symptoms.
However, the trial court and subsequent higher court findings determined that while Puno had a history of mental illness, he was legally sane during the commission of the crime.

Whether the evidence supports Puno’s claim of insanity as a defense, given his history of chronic schizophrenia.

Did Puno lack the capacity to appreciate the wrongfulness of his act at the time he committed the killing?
Was the mental disorder so severe as to completely nullify his discernment and freedom of will?

Whether the aggravating circumstances — evident premeditation, abuse of superiority, and disregard of sex — were correctly identified and appreciated.

Is there sufficient evidence to categorize the killing as having been committed with premeditation?
How do the witness testimonies and behavioral observations support or refute these aggravating factors?

The appropriate legal classification and sentencing given the interplay of aggravating factors and mitigating or exculpatory circumstances (voluntary surrender and diminished will due to mild psychosis).

The correct application of the legal standards on insanity, specifically regarding the requirement that an accused must be completely deprived of reason and discernment at the time of the offense.