G.R. No. 223566 - People vs. Salvador, Sr. y Masayang

Accused-appellant, Junie (or Dioney) Salvador, Sr. y Masayang, faced five counts of murder filed under different criminal cases:

Criminal Case No. 17628 – Charged with killing his two-year-old son, Junie Salvador, Jr., constituting parricide under Art. 246 of the RPC.
Criminal Case No. 17629 – Charged with killing Rossana B. Realo, a 12‑year‑old minor, daughter of his live-in partner.
Criminal Case No. 17630 – Charged with killing his live‑in partner, Miraflor Realo, using treachery and evident premeditation.
Criminal Case No. 17631 – Charged with killing Mariz R. Masayang, a three‑year‑old minor, his niece.
Criminal Case No. 17632 – Charged with killing Jonessa R. Masayang, a 1‑year‑and‑2‑months‑old minor, his niece.

On February 11, 2011, around 6:00 a.m., the accused and his live‑in partner Miraflor Realo, accompanied by others, were seen en route to a barangay hall for the Pamilya Pantawid program.

The accused allegedly exhibited “sweet” behavior while interacting with Miraflor.
Later that day, while still at the barangay hall, suspicions arose when a bolo‑wielding, blood‑stained accused was observed.

Santos Masayang noticed the accused with blood on his arms and abandoned bolos.
Joy Masayang witnessed the accused chasing and hacking Miraflor from behind, dragging her by the hair.
Upon arrival of barangay and police personnel, the accused surrendered voluntarily while holding bolos.

Four dead children—Rosana, Mariz, Jannes, and Dioney, Jr.—were found in the accused’s residence.
The incident’s details, including the manner of attack, were corroborated by physical evidence (e.g., wounds on the victims’ bodies).

Testimonies of several witnesses (Joy Masayang, Melissa Masayang, Felixchito Salaysay, Santos Masayang, and Police Officer I Kim Aguspina) supported the occurrence of the heinous acts.

Psychiatric evaluation by Dr. Reagan Joseph Villanueva was tendered to support the defense of insanity, indicating that the accused was suffering from schizoaffective disorder.
The accused himself testified, acknowledging his memory loss of the incident but affirming knowledge of his victims.
The defense argued that his mental condition impaired his capacity to comprehend the wrongfulness of his acts.

The RTC found the accused-appellant guilty of the murders.
It ruled that the defense of insanity was not sustained due to the absence of clear and convincing evidence of a complete loss of reason at the time of the crimes.
The accused was sentenced to reclusion perpetua in each count, with additional orders to pay substantial civil, moral, exemplary, and temperate damages to the heirs of the victims.

The Court of Appeals (CA) affirmed the RTC decision, with minor modifications to the award of damages:

The CA reiterated that the sole issue was whether the accused was mentally insane at the time of the crimes.
It sustained that the post-incident psychiatric diagnoses could not prove the absence of the capacity for discernment during the commission of the crimes.
The appeal was ultimately dismissed for lack of merit.

Whether the trial court erred in not giving probative weight to the psychiatric evaluation by Dr. Reagan Joseph Villanueva which purportedly indicated that the accused suffered from schizoaffective disorder at the time of the crime.
Whether the conviction of the accused-appellant for the multiple murders should stand, particularly given the defense’s failure to conclusively prove insanity beyond reasonable doubt.