G.R. No. 264846 - CCC vs. DDD, EEE, FFF, GGG and HHH

The appellant, Evaristo Vaquilar, was charged in two separate informations with parricide—once for killing his wife and another for killing his daughter.
In addition to the killing, he was held responsible for wounding several other persons with a bolo.
The crimes were committed in circumstances where multiple witnesses testified to the events, and the physical evidence (e.g., the mortal wounds on his wife and the split skull of his daughter) corroborated the commission of the offenses.

Testified that he heard a commotion and rushed into the house, witnessing the appellant killing his wife and daughter.
Noted that the appellant wounded several persons, including young boys and girls, during the melee.
Described the appellant’s physical appearance during the incident—“eyes very big and red” and a “penetrating” look—interpreting these signs as evidence of him being “crazy.”
Asserted that an ordinarily rational man would not commit such acts unless he was in a state of irrationality.

Confirmed his participation in the capture of the appellant alongside Martin Agustin.
Recounted that the appellant had previously complained of head and stomach pains.
Described the appellant’s behavior during the incident as that of a madman, indiscriminately striking others.

Testified that the appellant experienced headache and stomach troubles days prior to the crime.
Reported that, despite appearing sad, the appellant suddenly ran downstairs and later pursued and even attacked her.
Used the term “crazy” to describe his erratic behavior, suggesting a deviation from normal conduct.

Observed the appellant’s behavior over a period of five months while they were incarcerated together.
Noted instances where the appellant appeared normally composed and others when he exhibited withdrawn or tearful behavior, vocalizing outbursts about the people around him.

Confirmed the presence of multiple mortal wounds: five on the wife’s head and a completely split skull in the daughter.
Observed that the appellant, during a brief examination in jail, did not present clear signs of mental derangement.

The court discussed the common confusion between “crazy” (a colloquial term) and legal definitions of insanity or non compos mentis.
Cited multiple precedents such as People vs. Mortimer, People vs. Foy, and others to delineate the difference between a temporary loss of control (passion) and genuine mental unsoundness.
Emphasized that acts committed in the heat of passion, regardless of their brutality, do not automatically equate to legal insanity.

Whether the appellant’s actions—killing his wife and daughter—and the accompanying violent behavior were the result of an insane condition or merely the product of unbridled passion or anger.
Determining if the observed “crazy” behavior, as described by several witnesses, legally qualifies as insanity, or if it represents a temporary emotional frenzy in the absence of a diagnosed mental disorder.

Whether the defense successfully demonstrated that the appellant had lost sanity, thus excusing him from criminal responsibility.
The extent to which the evidence provided by both the prosecution and defense could overcome the presumption of sanity in criminal cases.

How previous decisions, such as those in People vs. Mortimer, People vs. Foy, United States vs. Carmona, and State vs. Stickley, influence the assessment of the insanity defense.
Whether these precedents adequately address the distinctions between acts committed under impulsive anger and those committed under genuine mental derangement.