Case Summary (G.R. No. 30460)
Charges and Court Proceedings
Calines was charged with two counts: Criminal Case No. 16-CR-11674 (frustrated homicide) and Criminal Case No. 17-CR-11741 (murder). It was alleged that Calines attempted to kill Nida Calasiao Sabado and succeeded in killing her three-year-old son, Sky, through violent attacks with a piece of wood. During the arraignment, there was an intention to plead guilty, but this was later rescinded and a trial ensued.
Prosecution's Evidence
The prosecution presented several witnesses to establish the guilt of Calines, concentrating on the testimonies of Nida, who recounted the brutal assault, and Dr. Paolo Angelo R. Igama, who provided medical documentation regarding Sky's death and Nida's injuries. The evidence indicated that Sky died from severe traumatic brain injury due to the assault, while Nida suffered significant injuries but did not incur fatal wounds.
Defense's Argument
The defense invoked insanity as a ground for exculpation, asserting that Calines suffered from paranoid schizophrenia, which affected his mental state during the commission of the crimes. Psychiatrists testified regarding his condition but the defense faced challenges in proving that Calines was insane at the time of the crime. Historical medical records were introduced, but the temporal disconnect from the crime to the present diagnosis raised questions about their relevance.
RTC Ruling
In a consolidated judgment dated November 15, 2019, the Regional Trial Court (RTC) found Calines guilty beyond reasonable doubt of both charges. He was sentenced to reclusion perpetua for murder and given a penalty of imprisonment from four years to eight years for frustrated homicide. The RTC rejected the insanity defense for lacking sufficient evidence, citing that no corroborating witnesses confirmed Calines's impaired state during the commission of offenses.
CA Ruling
The Court of Appeals (CA) affirmed the RTC's ruling, modifying the guilty verdict for frustrated homicide to attempted homicide but largely agreeing on the conviction for murder. The CA held that the psychiatric evaluation was inadequate to substantiate a claim of insanity, especially considering Calines’s behaviors following the incident, which suggested awareness of the wrongfulness of his actions.
Legal Principles Applied
The Court reaffirmed the principles under Articles 248 and 249 of the Revised Penal Code concerning murder and attempted homicide, emphasizing that the elements were met, including intent to kill and the presence of qualifying circumstances such as treachery and the abuse of superior strength. The Court stipulated that the defense of insanity must be deeply substantiated by clear evidence demonstrating the accused's mental state at the time of the crime.
Finding on Insanity Defense
Ultimately, the Court found the defense of insanity unsubstantiated, highlighting that evidence presented failed to prove that Calines was insane when he committed the acts in question. The Court required medical proof of insanity existing at the time of the offense under Article 12 of the R
...continue readingCase Syllabus (G.R. No. 30460)
Case Background and Procedural History
- The case involves Fernan Calines y Magastino (Calines), accused of frustrated homicide and murder.
- The charges stem from two separate Informations filed before the Regional Trial Court (RTC) of La Trinidad, Benguet, Branch 63, with Criminal Case Nos. 16-CR-11674 (frustrated homicide) and 17-CR-11741 (murder).
- The Court of Appeals (CA) affirmed with modification the RTC’s judgment in June 2021, which found Calines guilty beyond reasonable doubt of the crimes charged.
- Calines filed an ordinary appeal seeking to reverse and set aside the CA ruling.
Factual Summary
- On December 19, 2016, Calines attacked Nida Calasiao Sabado with intent to kill by striking her several times with a piece of wood.
- Nida escaped and received timely medical assistance which prevented her death.
- On the same date, Calines also attacked Sky Sabado y Calasiao, Nida's three-year-old son, inflicting fatal wounds leading to his death four days later.
- The murder was qualified by treachery and abuse of superior strength; Calines was a fully grown adult; Sky was a minor incapable of self-defense.
- Calines initially intended to plead guilty but withdrew to plead not guilty later after psychiatric evaluation.
- Prosecution witnesses testified to establish Calines’ guilt; defense presented testimony claiming Calines suffered from schizophrenia paranoid type.
Legal Issues Presented
- Whether the Court of Appeals erred in upholding the conviction of Calines for murder and attempted homicide.
- Whether the defense of insanity was sufficiently proven to exempt Calines from criminal liability.
Evidence and Testimonies
- Prosecution witnesses included Nida, Dr. Paolo Angelo R. Igama (attending physician to victim Sky), and Tyler Tudayan (provided aid to Nida).
- Medical evidence included Sky’s death certificate citing severe traumatic brain injury and mauling as causes.
- Calines’ defense rested on psychiatric evaluation by Dr. Donnalyn G. Gamueda who diagnosed schizophrenia paranoid type based on 2018 examinations.
- Testimony from Calines’ sister, Gloria Domingo, corroborated h