Case Summary (G.R. No. 130487)
Pre-trial Motions and Mental Competence
At arraignment, defense counsel filed an urgent motion to suspend proceedings and commit Estrada for psychiatric evaluation at Baguio General Hospital, citing prior confinement for mental defect. The trial court questioned the accused, deemed his answers “intelligent,” and denied the motion on January 6, 1995, proceeding to arraignment and entering a not guilty plea on his behalf.
Trial Evidence
The prosecution presented four witnesses: the city autopsy physician, an eyewitness assistant to the Bishop, a responding police officer, and the victim’s sister. Evidence established that Estrada inexplicably ascended to the Bishop’s chair during confirmation, ignored requests to desist, and repeatedly stabbed Mararac with a knife. He was subdued by police and later found with a scabbard. The victim died of massive intrathoracic hemorrhage. Autopsy reports confirmed two stab wounds.
Demurrer to Evidence
After resting its case, the prosecution faced a demurrer to evidence asserting lack of treachery, presence of unlawful aggression, and Estrada’s insanity. The trial court denied the demurrer on August 21, 1995, and later denied reconsideration, compelling Estrada to present evidence.
Findings and Sentence by the Trial Court
On June 23, 1997, the RTC found Estrada guilty of murder with cruelty as aggravating circumstance and sentenced him to death, indemnification of heirs, actual expenses, and moral damages.
Issues on Appeal
Estrada appealed, contending that:
- He proved insanity by clear and convincing evidence, exempting him from liability under Article 12(1) RPC.
- The homicide lacked qualifying treachery and the cruelty finding was unwarranted if insanity were recognized.
Insanity as an Exempting Circumstance
Under Article 12(1) RPC, an insane person is exempt from criminal liability unless acting during a lucid interval. Insanity requires proof of total deprivation of reason at the time of the act by clear and positive evidence. Partial abnormalities do not suffice.
Competency to Stand Trial
Rule 116, Section 12 of the Rules of Criminal Procedure mandates suspension of arraignment if the accused appears unable to understand charges or plead intelligently due to mental condition. Competency involves capacity to consult counsel, understand proceedings, and make rational decisions. Denial of a fair trial by trying an incompetent accused offends due process.
Duty to Order Mental Examination
Given Estrada’s history of psychiatric confinement, lay observations of bizarre conduct, and requests by jail wardens for psychiatric evaluation, the trial court should have ordered a formal mental examination. A judge’s casual questioning cannot substitute for expert assessment. Dual-purpose psychiatric evaluation could have determined both competency and sanity at the time of the offense.
Due Process Violation and Relief
The tri
Case Syllabus (G.R. No. 130487)
Facts of the Case
- On December 27, 1994, during a confirmation rite at St. John’s Cathedral, Dagupan City, with over a thousand attendees.
- Appellant Roberto Estrada approached the altar uninvited and sat on the Bishop’s chair while the Bishop was giving final blessings.
- Witness Crisanto Santillan requested Estrada to vacate the chair; Estrada gripped the armrest and refused, saying in Pangasinense, “No matter what will happen, I will not move out!”
- Cathedral security guard Rogelio Mararac tapped Estrada’s hand with his nightstick twice; Estrada then drew a knife and stabbed Mararac below the left throat.
- Estrada attempted a second stab, which Mararac parried. Estrada proceeded to the microphone, shouted “Anggapuy nayan dia!” (“No one can beat me here!”), and sat on the Bishop’s chair again.
- Police SPO1 Conrado Francisco, alerted to the disturbance, ordered Estrada to drop the knife; Estrada complied and was wrestled to the ground by Chief Inspector Wendy Rosario.
- Mararac was rushed to the hospital but died minutes after arrival from cardiorespiratory arrest due to massive intrathoracic hemorrhage and stab wounds.
Information and Charge
- December 29, 1994 Information accused Estrada of murder under Article 248, RPC.
- Allegations: armed with a butcher’s knife, intent to kill with treachery, committed in a holy place of worship.
- Sought indemnity of not less than ₱50,000 and other consequential damages for the deceased’s heirs.
Arraignment and Pre-Trial Motions
- January 6, 1995 arraignment: Public Attorney’s Office filed an “Urgent Motion to Suspend Arraignment and to Commit Accused to Psychiatric Ward at Baguio General Hospital,” alleging mental defect from prior confinement at BGH psychiatric ward.
- City Prosecutor opposed. The trial court propounded questions motu proprio; Estrada answered “intelligently,” and the motion was denied.
- The court entered a plea of not guilty on Estrada’s behalf due to his purported refusal to plead.
Prosecution Evidence
- Four witnesses: Dr. Tomas Cornel (autopsy and death certificate), eyewitness Crisanto Santillan, SPO1 Conrado Francisco, and victim’s sister Rosalinda Sobremonte.
- Established sequence: Cathedral disturbance → Santillan’s warning → Mararac’s tapping → fatal stabbing → appellant’s announcement → police intervention.
- Autopsy findings (Exhibit A & B): two stab wounds (parasternal 2nd i