G.R. No. 172697 - People vs. Villanueva y Marquez

On January 21, 2000, appellant Reynaldo Villanueva y Marquez, then 31 years old, committed a series of brutal crimes.
He killed his 8-year-old niece, Angelica Villanueva, by boxing her head and kicking her multiple times, resulting in massive brain edema, cerebral contusion, and subdural hemorrhage.
He also mauled his nephews, Rexie Villanueva (5 years old) and Enrique Villanueva, Jr. (2 years old), with Rexie sustaining potentially fatal injuries (averted by immediate medical intervention) and Enrique, Jr. suffering a broken mouth and a four-day hospitalization.

The corresponding Informations were filed before the Regional Trial Court of Baguio City (Branch 6) under:

Earlier on the morning of January 21, 2000, the appellant consulted Dr. Clarette Rosario P. Dy at the Psychiatric Department of Baguio General Hospital for a routine check-up; he was prescribed medicines and allowed to go home.
He then visited the 456 Restaurant along Session Road, ordering several bottles of Red Horse beer.
After a leisurely stroll through various locations including Maharlika Livelihood Center and Burnham Park, he stopped by a videoke bar on Magsaysay Avenue, where he consumed more alcohol and engaged socially.
Upon returning home, after buying and cooking hot dogs because he was hungry, a verbal altercation ensued with his mother when she inquired about food, triggering his violent outburst that culminated in the crimes.

He was under the care of Dr. Dy for approximately four years.
He was diagnosed with schizophrenia, paranoid, episodic with interepisode residual symptoms characterized by intermittent psychotic signs and symptoms.

Testimony from his mother indicated he was prone to violent fits, especially when under the influence of alcohol or drugs.

Murder (Article 248 of the Revised Penal Code, as amended by Section 6 of Republic Act No. 7659).
Frustrated murder.
Attempted murder.

The court held that the appellant failed to overcome the presumption of sanity, noting:

His ability to vividly recount events leading up to the crime.
His abrupt lapse in response only at the moment of offense, with full recollection resuming afterward.

Reclusion Perpetua for murder with indemnifications for moral and civil damages.
An indeterminate sentence for frustrated murder (prision mayor to reclusion temporal) with corresponding indemnifications.
An indeterminate sentence for attempted murder (prision correccional to prision mayor) with indemnifications.

The trial court credited 4/5 of his preventive imprisonment pursuant to Article 29 of the Revised Penal Code.

The Court of Appeals affirmed the trial court’s decision with modifications, notably:

Recognizing the appellant’s schizophrenia as a mitigating circumstance under Article 13(9) of the Revised Penal Code.
Reducing the award for moral damages.
Modifying the penalty for attempted murder.

Notwithstanding the mitigating circumstances, the appellant was held liable as he was not completely deprived of reason; his vivid memory and subsequent remorse confirmed his sanity.

The principal issue on appeal was whether the appellant was guilty beyond reasonable doubt and whether the insanity plea was tenable given his mental state before, during, and after the crime.
The Supreme Court scrutinized the trial and appellate findings, respecting the factual determinations and concluding that the evidence did not warrant an exemption from criminal liability.

Whether the appellant is guilty beyond reasonable doubt of committing murder, frustrated murder, and attempted murder.
Whether the evidence conclusively overcomes the presumption of sanity, especially in light of the appellant’s claim of insanity.
Whether the appellant’s psychiatric condition (schizophrenia) mitigated his criminal liability without eliminating his responsibility due to retained awareness of his acts.
Whether the penalty for frustrated murder was properly computed by the lower courts, given the statutory requirements and the mitigating circumstances.