Title
Supreme Court
People vs. Domingo
Case
G.R. No. 184343
Decision Date
Mar 2, 2009
Jesus Domingo attacked a sleeping family in 2000, killing two and injuring others. Claiming insanity, his defense failed; court found him guilty of murder, frustrated murder, and attempted murder, rejecting insanity due to lack of proof.

Case Summary (G.R. No. 184343)

Incident Overview

On March 29, 2000, Domingo attacked the Indon family, armed with a kitchen knife and a screwdriver. He was charged in six criminal cases arising from the assault, including the murders of Marvin G. Indon and Melissa G. Indon, and attempted and frustrated murder of other family members, including children Jeffer and Michelle Indon.

Prosecution's Evidence

Witness testimonies formed a significant part of the prosecution's case. Raquel Indon recounted the incident, identifying Domingo unequivocally. She described how he forcibly entered their home, brandished his weapons, and attacked her and her children. Medical records also supported the severity of the attacks, corroborating witness statements about the nature and extent of injuries sustained by the victims.

Defense Claims

Domingo’s defense was rooted in claims of insanity. He testified that he experienced hallucinations and was unaware of his actions during the attack. A psychiatrist later diagnosed him with schizophrenia, but there was no evidence tying his mental state to the time of the crime. The defense attempted to argue that his mental condition exempted him from criminal liability.

Initial Verdict

On November 13, 2006, the Regional Trial Court (RTC) convicted Domingo of homicide and attempted homicide but found no qualifying circumstances for murder such as treachery. The court emphasized the credibility of eyewitness accounts, especially those from Raquel Indon, and found insufficient merit in the insanity defense.

Appeal and Modification by the Court of Appeals

Domingo appealed the decision. The Court of Appeals, on April 30, 2008, modified certain verdicts, reclassifying charges to murder based on the presence of treachery. The court held that Domingo's surprise attack on the sleeping victims constituted treachery, warranting a conviction for murder rather than homicide.

Penalties Imposed

The appellate court adjusted the penalties, imposing reclusion perpetua for the murders of Marvin and Melissa Indon and modifying the awards for civil indemnities and damages. The total of damages for hospitalization, burial, and actual expenses was recalibrated, with some claims reduced or denied for lack of evidence.

Final Decision of the Supreme Court

The Supreme Court affirmed the Court of Appeals ruling, finding no compelling reason to disturb the factual findings. It ruled that the testimony of Raquel Indon was credible and that Domingo's claims of insanity were unsubstantiated, given the lack of e

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