Case Digest (G.R. No. 223566)
Facts:
People of the Philippines v. Junie (or Dioney) Salvador, Sr. y Masayang, G.R. No. 223566, June 27, 2018, the Supreme Court Third Division, Martires, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the accused-appellant was Junie (or Dioney) Salvador, Sr., y Masayang.On February 11, 2011, five persons — Miraflor Realo (accused’s live-in partner), Rosana Realo (Miraflor’s 12-year-old daughter), Dioney (Junie) Salvador, Jr. (accused’s 2-year-old son), Mariz R. Masayang (3-year-old niece), and Jannes R. Masayang (1-year-old niece) — were killed in Kapalong, Davao del Norte. Accused-appellant was charged by five separate Informations (Crim. Case Nos. 17628–17632) with parricide (for the killing of his son under Art. 246, Revised Penal Code) and murder (for the other victims under Art. 248, Revised Penal Code), the murder counts alleging qualifying circumstance(s) including treachery and evident premeditation in some instances.
At trial, prosecution witnesses included Joy Masayang, Melissa Masayang, Felixchito Salaysay, Santos Masayang, and PO1 Kim Aguspina, who described seeing the accused with blood and bolos, Joy witnessing the attack on Miraflor, discovery of the dead children inside the accused’s house, and the accused’s calm surrender to barangay authorities. The defense presented psychiatrist Dr. Reagan (or Regan) Joseph Villanueva and the accused, who testified that he remembered the victims but claimed amnesia as to the commission of the killings; the defense also relied on Dr. Giola Fe Dinglasan’s later psychiatric records indicating a diagnosis of schizoaffective disorder.
The Regional Trial Court (RTC), Branch 2, Tagum City, in a 12 July 2013 Joint Decision (penned by Judge Ma. Susana T. Baua) found the accused guilty as charged of parricide and multiple murder, imposed reclusion perpetua for each death, and ordered the accused to pay P50,000.00 civil and P50,000.00 moral damages to each heir. The accused appealed to the Court of Appeals (CA).
The CA, Twenty-Third Division, in a 27 January 2016 Decision (CA-G.R. CR-HC No. 01195-MIN, penned by Associate Justice Ruben Reynaldo G. Roxas, with Associate Justices Edgardo T. Lloren and Rafael Antonio M. Santos concurring) dismissed th...(Subscriber-Only)
Issues:
- Did the courts below err in not giving probative weight to the psychiatric evaluation and testimony that accused-appellant suffered from schizoaffective disorder, thereby establishing insanity as an exempting circumstance under Article 12(1) of the Revised Penal Code?
- Did the prosecution fail to prove the accused’s guilt beyond reasonable dou...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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