Case Summary (G.R. No. 214444)
Key Dates and Procedural History
• March 20, 2005 – Alleged commission of murder
• January 24, 2012 – RTC of Rosario, Batangas, convicts accused of murder (reclusion perpetua; ₱50,000 civil indemnity)
• March 13, 2014 – CA affirms RTC decision in toto
• November 17, 2020 – Supreme Court En Banc resolves appeal
Applicable Law
• 1987 Philippine Constitution – presumption of innocence; due process; right to fair trial
• Revised Penal Code (RPC) Article 12(1) – exemption for “imbecile or insane person” unless lucid interval; directs confinement in mental facility
• Rules of Court Rule 130, Section 50(c) – competency of witnesses to testify on mental sanity
Facts Established at Trial
• Witnesses saw accused hack sleeping victim with bolo using treachery and premeditation
• Police found accused 25–30 meters away, attempted flight, arrested with bolo in hand
• Post-mortem by municipal health officer confirmed fatal incised wounds
• Defense presented accused and mother; accused claimed long-standing depression and no recollection; mother described past sleeplessness, agitation, “blank stare”
Legal Insanity: Standard and Evolution
• Historic Formigones Test (1950): complete deprivation of intelligence or will at time of crime
• Recognized two sub-tests:
– Cognition: total loss of reason or capacity to discern right from wrong
– Volition: total loss of freedom of will
• Criticism: all-or-nothing view; rejects spectrum of contemporary psychiatry
• Supreme Court’s clarified three-way test:
- Insanity present at the time of the offense
- Insanity, as primary cause of act, must be medically proven
- Insanity’s effect must be inability to appreciate nature/quality or wrongfulness of act
Burden and Quantum of Proof
• Presumption of sanity under RPC Article 12 and Constitution
• When insanity is pleaded, burden shifts to defense to overcome presumption
• Supreme Court harmonizes with similar defenses of confession and avoidance: proof by clear and convincing evidence, not beyond reasonable doubt
Role of Expert Evidence and Mental Examination
• Medical experts best placed to diagnose and testify on mental disorders and their legal implications
• Lay witnesses competent if intimately acquainted, but cannot substitute expert opinion on causation and legal insanity
• Trial courts may, in proper circumstances, order an independent psychiatric examination to determine competency to stand trial and state of mind at offense
Application to Accused-Appellant
• Only lay testimony came from accused and his mother; no expert psychiatric testimony or court-ordered examination
• Mother’s observations related to periods long before offense, not immediately before or during; described agitation and sleeplessness but not
Case Syllabus (G.R. No. 214444)
Facts of the Case
- On March 20, 2005 at about 7:30 a.m., in Barangay Masaya, Rosario, Batangas, the accused-appellant Lito Paaa y Inandan attacked Sherwin Macatangay y Lara with a two-foot long bolo, inflicting incised wounds on the victim’s head and neck.
- Witness Aldwin Andal arrived at the victim’s hut, saw Macatangay sleeping on a bed, and observed the accused hacking the sleeping victim without warning; Andal fled and reported the incident.
- Police Officers PO3 Andres Mancia and PO1 Ronilo Balita were dispatched to the scene, discovered the victim’s lifeless body, and apprehended the accused 25–30 meters away, lying in a grassy lot with the bolo in hand as he attempted to flee.
- Municipal Health Officer Dr. Emelita Abacan performed the post-mortem examination, confirming four incised wounds as the direct cause of death.
Procedural History
- The accused pleaded not guilty; trial on the merits ensued.
- Prosecution presented four witnesses: the victim’s mother, Andal, PO3 Mancia, and Dr. Abacan.
- Defense presented the accused and his mother, Soledad, invoking insanity as a defense and describing past mental disturbances, sleeplessness, depressive episodes, two suicide attempts, and memory lapses.
- The Regional Trial Court convicted the accused of murder for failure to prove legal insanity and sentenced him to reclusion perpetua, ordering payment of ₱50,000 death indemnity.
- The Court of Appeals affirmed in toto, holding that the accused and his mother were not competent to testify on the accused’s insanity and that legal insanity was not established.
- The Supreme Court required supplemental briefs, set down the sole issue of whether the accused is exempt from criminal liability due to insanity, and conducted plenary resolution.
Issue
- Whether accused-appellant Lito Paaa y Inandan may claim exemption from criminal liability under Article 12(1) of the Revised Penal Code by reason of insanity.
Applicable Law on Insanity Defense
- Revised Penal Code, Article