Title
People vs. Pilen
Case
G.R. No. 254875
Decision Date
Feb 13, 2023
Pilen's violent rampage in 2013 resulted in 3 deaths, 8 frustrated murders, and 2 attempted murders; insanity defense rejected, convictions modified.

Case Summary (G.R. No. 254875)

Charges and Informations

Thirteen consolidated criminal cases charged Pilen with three counts of Murder and ten counts of Frustrated Murder (variously described in the records), arising from multiple attacks on July 14, 2013. The Informations in several counts alleged attendant qualifying circumstances such as treachery and evident premeditation; in other counts the phrasing was defective for lack of factual averments specifying how such circumstances attended the acts.

Factual Background (Prosecution Version)

The prosecution’s evidence, drawn from eyewitness testimonies and attending physicians, recounts that at about 7:00 p.m. on July 14, 2013, Pilen suddenly produced and used a bolo to stab and hack multiple persons in the community. Victims included Princess Aclao Jabonero, Maria R. Felicilda, an infant Leslie/Leslie Ann Salem Kaindoy (one year old), and numerous other adults who sustained stab or hacking wounds. Some victims died (Princess, Maria, and the infant), while others survived owing to medical intervention. The weapon was recovered and Pilen was arrested.

Defense Version

Pilen testified that earlier the same day he had been coerced to inhale and ingest a substance while drinking with others; he claimed loss of consciousness and lack of recollection of the events. A urine test (Exhibit K) reportedly showed THC metabolites. No medical expert was presented by the defense to establish mental incapacity or intoxication as causative of the conduct.

RTC Findings and Sentencing

The RTC found Pilen guilty beyond reasonable doubt of three counts of Murder (leslie ann, Maria, Princess), eight counts of Frustrated Murder, and two counts of Attempted Murder. The RTC adjudged Pilen competent to stand trial after a court-ordered psychiatric evaluation. The court rejected the insanity defense as unsubstantiated and self-serving. Sentences included reclusion perpetua for each Murder count and indeterminate terms for frustrated and attempted counts, with specific amounts of civil indemnity, moral, exemplary, and exemplary damages ordered for various victims.

Court of Appeals Ruling

The CA affirmed the RTC decision with modification. It reduced convictions in several counts from Murder to Homicide or from Frustrated Murder to Frustrated Homicide where it found the Informations defective for failing to particularize qualifying circumstances (treachery, evident premeditation). The CA increased some damage awards (e.g., exemplary damages for the infant victim) and ordered additional temperate damages and parole ineligibility for the infant-victim murder conviction.

Issue on Review by the Supreme Court

The Supreme Court’s primary question was whether the CA correctly affirmed Pilen’s convictions and whether the RTC and CA correctly appreciated qualifying circumstances (treachery, evident premeditation), the stages of the felonies, the insanity defense, and the admissibility/probative weight of medical expert testimony.

Governing Legal Principles Regarding Informations and Waiver

Under the 1987 Constitution a person charged must be informed of the nature and cause of the accusation. Jurisprudence requires that an Information alleging qualifying or aggravating circumstances (e.g., treachery, evident premeditation) must state ultimate facts showing how those circumstances attended the commission of the crime; mere conclusory language is insufficient. Remedies for defective Informations include a motion to quash under Section 3(e), Rule 117, or a motion for a bill of particulars. Failure to timely pursue those remedies constitutes waiver of the defect, allowing the particular circumstance to be proved at trial and appreciated against the accused.

Application to Treachery and Evident Premeditation

The Court found the Informations deficient in many counts for not describing the factual basis of treachery or evident premeditation. However, Pilen did not file a motion to quash or ask for a bill of particulars and voluntarily pleaded not guilty and proceeded to trial; therefore he waived the right to contest the defect. Treachery was, however, properly appreciated in the killing of the infant Leslie Ann because the victim’s tender age alone suffices to characterize the killing as treacherous: a child of tender years is inherently defenseless, and jurisprudence treats the killing of such a child as ipso facto qualified by treachery. For the other victims, the Court held that neither treachery nor evident premeditation was proved beyond reasonable doubt: suddenness and unexpectedness alone do not establish treachery unless the mode of attack was consciously adopted to insure the assailant’s safety from defense or retaliation; evident premeditation requires clear proof of a cool, pre-existing resolution and sufficient interval for reflection, which the records did not show.

Stages of the Felony: Consummated, Frustrated, Attempted

The Court applied Article 6 of the RPC and settled jurisprudence to determine the stage of each offense. For Princess and Maria the offenses were consummated homicides (all elements executed and victims died). For Roger, Wenefredo, Genara, Love Joy, Jolito, April Rose, and Aiza the acts amounted to frustrated homicide because the accused performed all acts of execution and the victims’ deaths were averted only by timely medical intervention. For Georgia and Zenaida the injuries were non-fatal and thus characterized as attempted homicide. For Maximo the prosecution failed to present competent testimony establishing the fatality of his wound; the medical certificate alone, without the attending physician’s testimony, was insufficient to show that the wound would have been fatal absent medical assistance, so the Court resolved doubts in favor of the accused and characterized the offense as attempted homicide.

Expert Testimony and Objection Timing

The defense argued that the trial court improperly credited testimony of Drs. Sibud and Borres without establishing them as experts. The Court emphasized procedural rules under Sections 35 and 36, Rule 132 of the Rules of Court: objections to offered evidence must be raised at the time of offer or immediately upon the appearance of the ground for objection. The defense did not timely object to these doctors’ qualifications or their testimonies and did not cross-examine; thus any objection was waived. Admissibility of evidence is distinct from probative value, and the trial court’s assessment of expert credibility is accorded wide discretion and not disturbed absent abuse.

Insanity Defense and Burden of Proof

Insanity is an exculpatory defense that admits the act but seeks exemption from criminal liability by proving lack of volition or intelligence. The three-part test (as applied in precedent) requires that insanity be present at the time of the offense, be medically proven as the primary cause of the act, and result in inability to appreciate the nature or wrongfulness of the act. The Court found Pilen’s claim of insanity unproven: he offered no competent medical expert testimony showing a mental disease contemporaneous with the acts, and his own testimony and the positive toxicology for THC metabolites did not establish that any mental disorder caused the violent conduct or that intoxication rendered him criminally irresponsible. The Court noted that drug intoxication, under RA 9165, can be an aggravating circumstance,

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