Case Summary (G.R. No. 57883)
Facts of the Case
On the afternoon of September 8, 1970, Puno entered the bedroom of Aling Kikay and verbally insulted her before physically assaulting her with a hammer, resulting in her death. The attack was witnessed by Hilaria de la Cruz and Lina Pajes, who testified about Puno’s aggressive demeanor and threats to them afterward. Puno fled the scene but later was apprehended after his father turned him in to the police.
Evidence and Medical Examination
A medico-legal officer confirmed Aling Kikay's cause of death as intracranial traumatic hemorrhage due to blunt force. Puno had a history of psychiatric issues, being treated intermittently for schizophrenia from 1962 until shortly before the incident. During his psychiatric evaluations, three psychiatrists testified that while Puno had mental health issues, he was not insane at the time of the killing, indicating he understood his actions.
The Trial and Its Rulings
The trial court found Puno guilty of murder, applying the aggravating circumstance of abuse of superiority due to the disparity in physical strength between Puno and the unarmed victim. Puno's claims of insanity were dismissed as insufficient, as the court demonstrated that he had not lost the capacity to appreciate the nature of his actions.
Aggravating and Mitigating Circumstances
The court recognized the abuse of superiority in Puno's actions but ruled out evident premeditation due to a lack of evidence showing prior intent. Disregard of the victim's age was considered an aggravating circumstance, while Puno's voluntary surrender and mental state were acknowledged as mitigating factors. Ultimately, the trial court sentenced Puno to death and ordered indemnity for the victim's heirs.
Supreme Court Decision
Upon review, the Supreme Court overturned the death sentence, concluding that Puno should be sentenced to reclusion perpetua instead. The ruling emphasized that Puno, although mentally ill, was not entirely devoid of reason during the commission of the crime. The court notably clarified that "social recovery" does not equate to full mental recovery. The indemnity imposed by the trial court was upheld, ensuring the victim’s heirs received compensation.
Dissenting Opinion
Justice Makasiar dissented, arguing that Puno was indeed mentally ill at the time of the crime, suffering from chronic schizophrenia, which impaired his c
...continue readingCase Syllabus (G.R. No. 57883)
Case Overview
- The case involves the murder of Francisca Col (Aling Kikay), a 72-year-old widow, by Ernesto Puno, a 28-year-old jeepney driver.
- The incident occurred on September 8, 1970, in Little Baguio, Barrio Tinajeros, Malabon, Rizal.
- Puno's defense centers on the claim of insanity, arguing that he was mentally incapacitated at the time of the crime.
Facts of the Case
- At approximately 2:00 PM on the day of the incident, Puno entered Aling Kikay's bedroom and verbally assaulted her, accusing her of being a witch.
- Puno proceeded to slap her and struck her multiple times with a hammer, resulting in her death.
- The attack was witnessed by Hilaria de la Cruz and Lina Pajes, who noted Puno's threatening demeanor and bloodshot eyes.
- After the murder, Puno threatened the witnesses to refrain from contacting the police and fled to various locations, including his parents' home and a cousin's house in Bulacan.
Evidence Presented
- Corporal Daniel B. Cruz, responding to a police call, discovered the victim dead in her bed, with visible signs of trauma and blood.
- A medico-legal officer conducted an autopsy, confirming death from traumatic hemorrhage.
- Witnesses, including the victim's housemates, identified Puno as the assailant.
Accused's Background and Mental Health
- Puno had a history of mental health issues, specifically chronic schizophrenia, which he had been treated for since 1962.
- His behavior leading up to the crime included erratic actions and delusions, such as believing in the existence of w