Case Digest (G.R. No. 216021)
Facts:
Petitioner Solomon Verdadero y Galera was charged in an Information dated September 9, 2009 with killing Romeo B. Plata on March 12, 2009 in Baggao, Cagayan; he pleaded not guilty on June 3, 2011, invoked the defense of insanity at pre-trial, and was tried. The Regional Trial Court convicted him of homicide on May 30, 2013; the Court of Appeals affirmed on July 10, 2014 and denied reconsideration on December 15, 2014, prompting this petition for review.Issues:
- Whether the Court of Appeals erred in affirming the conviction despite the claim that insanity at the time of the stabbing was established by clear and convincing evidence?
- If acquitted by reason of insanity, whether the accused remains civilly liable to the heirs of the victim and what remedies follow?
Ruling:
The petition was granted and Solomon Verdadero y Galera was ACQUITTED of homicide by reason of insanity; he was ordered confined at the National Center for Mental Health for treatment and to be released only Case Digest (G.R. No. 216021)
Facts:
- Background and procedural posture
- The Information dated September 9, 2009 charged Solomon Verdadero y Galera with murder under Article 249 of the Revised Penal Code for the alleged killing of Romeo B. Plata on March 12, 2009, alleging the use of a Rambo knife, intent to kill, evident premeditation, and treachery.
- On June 3, 2011, Verdadero was arraigned and pleaded "Not Guilty"; at pre-trial he invoked the defense of insanity and declined a reverse trial; trial followed.
- The Regional Trial Court (RTC), Branch 03, Tuguegarao City rendered judgment on May 30, 2013 finding Verdadero guilty of homicide and imposing an indeterminate sentence described in the RTC decision and awarding P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P30,000.00 as stipulated actual damages.
- The Court of Appeals (CA) in CA-G.R. CR No. 35894 affirmed the RTC judgment in a July 10, 2014 Decision; the CA denied reconsideration in a December 15, 2014 Resolution.
- Verdadero filed a petition for review under Rule 45, assailing the CA’s affirmation on the ground that his insanity at the time of the incident was established by clear and convincing evidence.
- Facts of the incident and evidentiary record
- On March 12, 2009 at about 3:00 p.m., Maynard Plata and his father Romeo went to Baggao Police Station to report an alleged theft of a fan belt by Verdadero; after a confrontation they took a tricycle, stopped at a drugstore, and separated briefly.
- Maynard testified he saw Verdadero stab Romeo after being alerted by Ronnie Elaydo; Verdadero allegedly stabbed Romeo on the left upper back and again below the right shoulder, attempted to attack Maynard, and was resisted with a small stool.
- Ronnie ran to the police station; responding officers arrested Verdadero; Romeo was transported to Cagayan Valley Medical Center and died upon arrival; the Post-Mortem Examination Report attributed death to cardiopulmonary arrest secondary to severe hemorrhage secondary to multiple stab wounds and hack wounds.
- Defense evidence established a longstanding psychiatric history for Verdadero: outpatient treatment at Cagayan Valley Medical Center (CVMC) Psychiatric Department since 1999; diagnosis of depression in 2001; confinement in 2001 for two months; diagnosis of schizophrenia on July 21, 2003; irregular consultations and multiple admissions with a fourth confinement in 2009 following a relapse.
- On March 12, 2009 nurses observed Verdadero removing IV tubes and locking himself in a comfort room; he was sedated and placed in isolation; Dr. Leonor Andres-J...(Subscriber-Only)
Issues:
- Main substantive issue
- Whether the Court of Appeals gravely erred in affirming Solomon Verdadero y Galera's conviction despite the asserted proof that his insanity at the time of the incident was established by clear and convincing evidence.
- Procedural issue on scope of review
- Whether the Supreme Court may review the factual determination of insanity in a petition for revie...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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