G.R. No. 256468 - People vs. Villa y Garcia

Arvi Villa y Garcia (accused-appellant) was charged in three separate Informations with:

Two counts of Murder (Crim. Case Nos. 14-307999 and 14-308000) under Article 248 of the Revised Penal Code (RPC), as amended.
One count of Frustrated Murder (Crim. Case No. 14-308001) under Article 248 in relation to Article 50 of the RPC.

The incidents occurred on or about August 1, 2014, in the City of Manila.
The accused was alleged to have with intent to kill, with treachery and evident premeditation, shot Sergio Aguilar, Jr. (victim in first murder charge), Maria Lourdes Aguilar (victim in second murder charge), and Maridref Tolentino y Rico (victim in frustrated murder charge).
Accused-appellant pleaded “Not Guilty” during arraignment.

Testimonies were given by: Maridref Tolentino (private complainant), Police Officer Ruel Villaranda, witnesses Lemuel Vallenas, Police Chief Inspectors Cristina Macagba, Liza Octaviano-Ang, Jiselle Baluyot, and relatives Alfredo Aguilar and Alexander Rico Tolentino.
Maridref testified that she was the live-in partner of accused-appellant for seven years and that she endured physical and verbal abuse since 2011. She broke up with him in June 2014 and moved to her mother’s house.
On August 1, 2014, accused-appellant came to Sta. Ana, Manila; after unsuccessful attempts to reconcile, he suddenly shot at Maria Lourdes and Sergio, killing them instantly, and wounded Maridref who managed to escape and get medical help.
Medical certificates confirmed multiple gunshot wounds on Maridref; medico-legal reports confirmed fatal head wounds on Maria Lourdes and Sergio.
Police officers and witnesses recalled the sequence of events, including accused-appellant’s attempt to shoot himself after the incident.

Accused-appellant could not clearly recall the events of August 1, 2014, and claimed he only remembered going to Maridref’s house to fetch her and later waking up in the hospital.
He was unsure if he shot the victims, stating this after hearing Maridref’s testimony.
The defense later raised the exempting circumstance of temporary insanity as a ground for appeal though it was not raised at trial.

The Regional Trial Court (RTC), in its consolidated decision dated August 29, 2018, found accused-appellant guilty beyond reasonable doubt of two counts of Murder and one count of Frustrated Murder, emphasizing treachery and evident premeditation.
The Court of Appeals (CA), in its Decision dated September 30, 2020, affirmed the RTC ruling with modification on damages awarded for the Frustrated Murder case and rejected accused-appellant’s defense of insanity.

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for two counts of Murder and one count of Frustrated Murder without appreciating the exempting circumstance of insanity.
Whether the killing of Maridref Tolentino ought to be classified as Frustrated Murder or Attempted Murder considering the nature of her injuries.
Whether the Informations charging the accused-appellant were sufficient despite non-pleading of factual averments on the qualifying circumstance of treachery.
The appropriate penalties and awards of damages corresponding to the crimes committed and proven.