Case Summary (G.R. No. 103974)
Case Background
Ariel Catanyag was convicted of parricide for the murder of his wife, Elizabeth, sentenced to reclusion perpetua, and ordered to indemnify the heirs of the deceased in the amount of P50,000.00 along with the payment of costs. The incident occurred on December 9, 1988, when Catanyag unlawfully entered the residence of Elizabeth's sister, Girlie Nery, searching for Elizabeth, who had distanced herself from him after their separation.
Incident Description
On the afternoon of December 9, 1988, Catanyag followed Elizabeth into a comfort room after a quarrel wherein he insisted she return to live with him. Despite Elizabeth's attempts to evade him, the situation escalated into a violent confrontation, resulting in Catanyag stabbing Elizabeth multiple times. Girlie Nery witnessed the stabbing after hearing Elizabeth's calls for help and intervened. Elizabeth was eventually taken to the hospital but died shortly after due to severe hemorrhage.
Defense Claim
During the trial, the defense sought to establish that Catanyag was suffering from insanity at the time of the crime. The only supporting evidence presented was from Dr. Edgardo Canlas, who conducted a psychiatric evaluation two years post-incident, diagnosing Catanyag with an “organic mental syndrome” characterized by irritability and poor impulse control. However, Dr. Canlas also stated that his intelligence was average and that his physical and neurological examinations showed normal results.
Trial Court Findings
On September 20, 1991, the trial court convicted Catanyag of parricide, stating that the medical findings did not convincingly establish that his mental condition at the time of the offense was as described in his later evaluation. The court highlighted that the burden of proof lies with the defendant to demonstrate that he was completely deprived of reason when committing the crime — a standard under Article 12 of the Revised Penal Code.
Legal Considerations
Article 12 of the Revised Penal Code specifies that a person who is insane or an imbecile is exempt from criminal liability, unless they acted during a lucid interval. To claim this exemption successfully, the accused must provide clear evidence of a complete deprivation of
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Case Overview
- The case involves Ariel Catanyag y Sta. Ana, who appealed against the decision of the Regional Trial Court of Antipolo, Rizal, which convicted him of parricide.
- The trial court sentenced him to reclusion perpetua and ordered him to indemnify the heirs of his deceased wife, Elizabeth Catanyag y Calderon, in the amount of P50,000.00, along with the payment of costs.
- The case highlights the legal principles surrounding parricide and the defense of insanity.
Factual Background
- Ariel Catanyag and Elizabeth Calderon were legally married on August 18, 1983, in Cainta, Rizal.
- By December 1988, the couple had separated, with Elizabeth staying at her sister Girlie Nery's house in Taytay, Rizal.
- On December 9, 1988, Ariel entered Girlie’s house without permission, searching for Elizabeth.
- A confrontation ensued between Ariel and Elizabeth, during which he attacked her with a 'Batangas knife 'vente nueve' (29).
- Girlie Nery witnessed the attack and attempted to intervene but was threatened by Ariel.
- Elizabeth suffered multiple stab wounds and later died from severe hemorrhage shortly after being take