G.R. No. 225599 - People vs. Roa

Accused-appellant Christopher Mejaro Roa was reported to have suffered from a mental disorder prior to the commission of the crime.
Testimonies indicate that his mental issues may have originated either from an incident in 2000—when he was struck on the head by teenagers—or from alleged drug use during his stint in Manila.
His behavior reportedly changed after his return from Manila in 2001, becoming markedly talkative, exhibiting tendencies of talking to himself, and complaining of headaches.
He experienced a psychotic episode on September 27, 2001, which led to his confinement at a mental hospital.
Subsequent psychiatric evaluations and hospital confinements in the early 2000s (2001–2005) established his diagnosis of schizophrenia, with recurring issues noted when he interrupted his medication due to financial constraints.

On March 16, 2007, at around 3:30 p.m. in Barangay San Miguel, Bula, Camarines Sur, Eliseo Delmiguez, aged 50, was walking with a companion when the incident occurred.
From a distance of about three meters, Roa, who was observed sitting on a trimobile, approached the pair from behind.
Accused-appellant suddenly attacked and stabbed Delmiguez on the left lower back with a bladed weapon locally known as “ginunting” (a bolo approximately 8 to 12 inches in length).
The stabbing was accompanied by multiple mortal hack wounds that were established as the proximate cause of the victim’s death.
After the attack, both Edgar and Rico, who were present, chased the accused, who in turn fled and sought refuge in his uncle Camilo Mejaro’s house.

Following the stabbing, the disturbance attracted attention from local residents and police authorities; Barangay Captain Herminion Ballebar and SPO1 officers intervened.
Upon encountering the accused at the uncle’s house, law enforcement officers called on him to surrender.
Accused-appellant voluntarily surrendered and handed over the weapon, after which he was taken into custody at the Bula Municipal Police Station.
The victim, Eliseo Delmiguez, was pronounced dead on arrival at the local health center; necropsy confirmed death due to hypovolemia secondary to multiple stab wounds.

During arraignment, the accused-appellant pleaded “not guilty” and, intriguingly, signed his certificate of arraignment under the name “Amado M. Tetangco.”
The Regional Trial Court (RTC) of Pili, Camarines Sur, in its decision dated September 3, 2013, found Roa guilty of murder under Article 248 of the Revised Penal Code.
The RTC ruled that the defense of insanity, which was interposed by the accused, was not sufficiently proven because it failed to establish that he was completely deprived of reason or that he acted without the least discernment at the time of the crime.
The RTC sentenced accused-appellant to reclusion perpetua and imposed civil, moral, and exemplary damages payable to the victim’s heirs.

The Court of Appeals (CA) affirmed the RTC’s decision, modifying the award of damages while reiterating that all elements of the crime of murder were sufficiently established by evidence.
The CA found that the evidence supporting the accused’s claim of insanity—based on testimony relating to his past mental hospitalizations and abnormal behavior—was speculative and did not convince the court that he was insane at the time of the commission of the crime.
On appeal, the Supreme Court reviewed the case, specifically focusing on whether sufficient evidence existed to uphold the conviction in light of the accused’s plea of insanity.

Whether the evidence presented was clear and convincing enough to establish that Roa was insane at the time he committed the stabbing.
Whether prior mental hospitalizations and diagnoses (specifically in 2001 and 2012) could be extended to cover his mental state during the commission of the crime in 2007.

Whether the actions exhibited by the accused—such as attacking from behind, fleeing the scene, and issuing a voluntary surrender—demonstrate the presence of rationality and conscious intent.
Whether the defense successfully bridged the gap regarding his state of mind between his earlier confinement and the commission of the offense.