Case Digest (G.R. No. 129291)
Case Digest (G.R. No. 129291)
Facts:
People of the Philippines v. Enrico A. Valledor, G.R. No. 129291, July 03, 2002, First Division, Ynares‑Santiago, J., writing for the Court. The accused‑appellant is Enrico A. Valledor; the respondent is the People of the Philippines as plaintiff‑appellee.Three informations were filed against Valledor: Criminal Case No. 9359 for the murder of Elsa Villon Rodriguez (stabbing to the chest on March 6, 1991); Criminal Case No. 9401 for attempted murder of Ricardo Maglalang (stabbing that did not cause death); and Criminal Case No. 9489 for frustrated murder of Roger Cabiguen (stab wound to the right forearm). After his arrest Valledor was intermittently confined at the National Center for Mental Health (NCMH); he was arraigned on February 19, 1993, and in November 1994 was declared mentally fit to stand trial. At trial he admitted committing the acts but pleaded the exempting circumstance of insanity; the lower court conducted a reverse and joint trial.
The prosecution’s evidence established that on March 6, 1991 Valledor entered a room where Roger, Elsa and others were working, called Roger’s nickname (“Jer”), attacked and stabbed Roger (right forearm), then stabbed Elsa in the chest, uttered “Ako akabales den, Elsa” (I had my revenge, Elsa), and fled; two other occupants were left unharmed. Elsa was dead on arrival at the hospital; Roger survived with a 5‑centimeter forearm wound. Witnesses also reported that a neighbor, Ricardo Maglalang, was stabbed outside.
The defense introduced evidence of Valledor’s prior and subsequent aberrant behavior and medical examinations. Before the incident Valledor’s mother reported restlessness and insomnia in January 1990; Dr. De Guzman diagnosed psychosis with schizophrenia and prescribed Thoracin. On March 6 Valledor had been seen behaving oddly (crying, swimming clothed, telling others his family would be killed), was brought toward Puerto Princesa by barangay officials, jumped off a jeepney, and later was found by his mother saying “Pinatay niya kayong lahat.” Post‑offense medical reports—Dr. Manuel Bilog’s recommendation and the NCMH April 27, 1992 findings by Dr. Guia Melendres—diagnosed schizophrenia and psychoactive substance (alcohol) abuse and recommended commitment.
On February 28, 1997 the Regional Trial Court (Branch 47, Palawan and Puerto Princesa City) convicted Valledor of murder (Crim. No. 9359), frustrated murder (Crim. No. 9489), and attempted murder (Crim. No. 9401), imposed successive penalties (including reclusion perpetua), ordered indemnities, and suspended service of sentence pursuant to Article 12 and 79 of the Revised Penal Code because of his certified mental disorder, committing him to NCMH pending fitness to serve sentence. Valledor appealed, contending he was legally insane at the time of the offenses. He brought the appeal to the Supreme Court.
Issues:
- Was Valledor legally insane at the time he committed the stabbing offenses, such that he is exempt from criminal liability?
- Did the wound inflicted upon Roger Cabiguen constitute frustrated murder or only attempted murder?
- Were the civil damages awarded by the trial court appropriate and properly supported by evidence?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)