Case Summary (G.R. No. 227312)
Facts and Procedural History
Jessie Haloc was apprehended immediately after the attack, which was precipitated by his initial attempt to attack the victims' father Ambrosio, who escaped. Armed with a bolo, Jessie hacked Allan on the arm and inflicted fatal wounds on Arnel. After arrest, he was subjected to psychiatric evaluation due to concerns about his mental capacity. He was later declared fit for trial and arraigned in 2010, pleading not guilty. His defense rested on insanity.
The RTC convicted Jessie of attempted murder and murder after rejecting his insanity defense, citing no evidence of total deprivation of reason. The CA affirmed the convictions with modification to damages awarded. The present appeal challenges the rejection of insanity as defense and the imposition of criminal liability.
Applicable Law: Murder and Insanity Defense
Under Article 248 of the Revised Penal Code, murder requires proof that a person was killed by the accused with qualifying circumstances such as treachery or superior strength. In this case, the killing of minors was considered treacherous per Supreme Court precedents because minors cannot effectively resist, making the assailant's attack essentially without risk.
Insanity is an exempting circumstance under Article 12, Section 1 of the Revised Penal Code and serves to absolve a person from criminal liability if there is complete deprivation of intelligence or reason at the time of the criminal act. The burden of proof for insanity lies with the accused and must be established by clear and convincing evidence.
Legal Standard on Insanity
The Supreme Court reaffirmed the test for insanity requiring a complete lack of discernment or cognition when the crime was committed. Mere abnormality or mental illness is insufficient unless it wholly incapacitates intelligence and free will. The Court applied precedents holding that insanity as a defense involves the accused acting without any sense or understanding of the nature or wrongfulness of the act at the time it was committed.
Evidence of mental condition before and after the offense may be considered, but what is decisive is the mental state during the act. The accused's conduct after the incident, including recognition of relatives and surrendering the weapon, negates the claim of total deprivation of reason.
Findings on the Accused's Mental State
Testimony and medical records showed Jessie had prior mental disorders treated with medication, but no proof established total insanity at the time of the offense. Psychiatrist testimony acknowledged management of psychosis but did not conclude the accused was lacking cognition during the assaults. The accused's behavior immediately after the attack indicated awareness and discernment.
The mere fact that the accused suffered from mental illness or underwent treatment was not sufficient to exempt him from criminal liability since the condition did not eliminate his capacity to understand or control his actions.
Court's Conclusion on Criminal Responsibility and Insanity Defense
The Supreme Court held that the accused's insanity defense failed for lack of evidence proving complete deprivation of reason at the time of the offenses. His actions demonstrated capacity to form intent, and the presumption of sanity applied. Thus, the convictions for murder and attempted murder were affirmed.
Moreover, the mental condition did not qualify as a mitigating circumstance since no evidence showed diminished will power.
Modifications to Awards and Penalties
In line with jurisprudence, the Court increased the civil indemnity, moral damages, and exemplary damages awarded to the victims or their heirs. For the murder victim Arnel de la Cruz, damages were adjusted to P75,000.00 for civil indemnity, moral damages, and exemplary damages each. For Allan de la Cruz, the amounts wer
...continue readingCase Syllabus (G.R. No. 227312)
Facts and Background of the Case
- Jessie Haloc y Codon, then 51 years old, was apprehended after hacking two minor brothers, Allan (9 years old) and Arnel de la Cruz (4 years old) inside their yard in Barangay Union, Gubat, Sorsogon on June 22, 2008.
- Arnel died instantly due to a lethal hacking blow severing the jugular veins and nearly decapitating his head; Allan sustained injuries on the upper arm.
- The accused was armed with a 24-inch bolo and initially attempted to strike their father, Ambrosio, who escaped.
- The attack took place around noon; accused pursued the children after Ambrosio’s escape.
- The accused was charged with Murder (Criminal Case No. 2781 for Arnel) and Attempted Murder (Criminal Case No. 2780 for Allan).
- The accused did not submit a counter-affidavit and was initially considered mentally unfit to stand trial, leading to a court-ordered psychiatric evaluation.
- After being declared fit on July 7, 2010, the accused was arraigned on July 22, 2010 and pleaded "not guilty."
- The accused claimed insanity as a defense and presented witnesses, including family members and a psychiatrist, to support this claim.
Trial Proceedings and Evidence
- The accused’s older sister, Araceli Haloc-Ayo, testified the accused was angry at the children for being noisy and acting fiercely with "blazing" eyes after the incident.
- Araceli noted the accused surrendered the bolo voluntarily and recognized her after the attack.
- The accused’s wife testified the accused was a kind person with a history of mental disorder treated in 2003; mental illness recurred in 2008 allegedly due to alcohol consumption.
- Psychiatrist Dr. Imelda Escuadra confirmed the accused was a patient at Don Susano Memorial Mental Hospital in 2003 and 2007 but had improved with medication.
- The prosecution did not present any evidence to counter the defense’s claim.
- The Regional Trial Court rejected the insanity defense, finding no evidence of complete deprivation of reason and affirmed the accused’s sanity presumption.
- The RTC convicted the accused for Murder and Attempted Murder with appropriate sentences and awards for civil indemnity and moral damages.
Court of Appeals Decision
- The Court of Appeals affirmed the RTC decision with modifications.
- It ruled that the accused’s mental condition was improved at the time of trial, showing no psychotic signs or substantial diminution of willpower.
- The CA deleted the award of medical expenses and imposed 6% interest on civil indemnity and moral damages from the judgment's finality date.
- The court refused to consider the accused’s mental condition as mitigating and maintained the convictions.
Issues on Appeal
- The accused-appellant claimed the de