Case Summary (G.R. No. 156252)
Facts of the Case
On June 17, 2008, Roland MiraAa y Alcaraz was charged with the murder of 73-year-old widow Dominga Agnas Vda. De Globo. The Information filed against him indicated that he attacked and killed the victim using a bolo with intent to kill and with abuse of superior strength. Notably, the victim had been fearful of the accused due to prior harassment. Following a plea of guilty, the RTC conducted a reverse trial, leading to his conviction for murder and a sentence of reclusion perpetua.
Prosecution's Argument
The prosecution presented evidence indicating that the victim was threatened prior to the incident, including physical harassment by the accused. Eyewitness accounts showed that shortly before the murder, the victim expressed fear about the accused's behavior. The police investigation revealed the accused admitting his guilt immediately after the incident, thus substantiating the prosecution’s claims regarding his accountability.
Defense's Argument
The defense sought to assert that the accused-appellant was insane at the time of the crime, utilizing testimonies from the accused’s mother and sister, as well as a psychiatrist. They described the accused’s disturbing behavior leading up to the incident, including believing the victim to be a witch. The defense's position hinged on the assertion that these factors negated his culpability for murder.
RTC Ruling
The RTC ruled against the defense of insanity, determining that while the accused demonstrated odd behavior, this did not equate to a total inability to discern right from wrong at the time of the crime. Consequently, the RTC concluded that the crime qualified as murder, considering the victim’s age and the absence of means to defend herself from the appellant's attack. The court sentenced him to reclusion perpetua and awarded various damages to the victim's heirs.
CA Ruling
The CA upheld the RTC decision but modified the award of damages. It affirmed the guilt of the accused-appellant for murder while agreeing that he failed to prove insanity as a valid defense. The court reiterated the standard for proving insanity and concluded that the appellant’s unusual behavior did not demonstrate a complete lack of understanding or rationality necessary for an insanity defense.
Supreme Court's Ruling
The Supreme Court found merit in the appellant's claims regarding the improper application of the qualifying circumstance of abuse of superior strength and decided to modify the conviction from murder to homicide. It determined that the prosecut
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Case Background
- This case involves an automatic review by the Supreme Court of the Philippines regarding the 7 August 2014 Decision of the Court of Appeals (CA), which upheld the Regional Trial Court's (RTC) ruling.
- The accused-appellant, Roland MiraAa y Alcaraz, was found guilty of murder and sentenced to reclusion perpetua by the RTC on 11 April 2013.
- The murder charge stemmed from an incident that occurred on 17 June 2008, where the accused allegedly killed 73-year-old Dominga Agnas Vda. de Globo with a bolo.
Facts of the Case
- The accused-appellant was charged with the crime of murder, specifically for the willful, unlawful, and felonious attack on the victim, resulting in her death.
- The victim had been living alone but had sought refuge with her cousin, Alberto MiraAa, due to prior harassment from the accused.
- On the morning of the incident, the victim was found lying dead in front of her house, and the accused confessed to the police that he was responsible for her death.
Version of the Prosecution
- The victim, Dominga, was known to be fearful of the accused due to his previous threats and harassment.
- On the day prior to the incident, she expressed fear to her cousin Alberto after being chased by the accused armed with a bolo.
- Witnesses, including neighbors, heard cries coming from the vicinity and found the victim on the ground, establishing a timeline leading to the discovery of the crime.
- Police officers, upon arrival, found the accused a