Case Summary (G.R. No. 126043)
Case Background and Charges
Roger Racal was charged with murder for stabbing Jose Francisco on April 19, 2006. The Information stated that Racal, armed with a knife, deliberately, with treachery and evident premeditation, attacked Francisco, resulting in fatal wounds causing his death. Racal pleaded not guilty and raised insanity as a defense during trial.
Facts Established at Trial
The prosecution established that early morning on April 19, 2006, while trisikad drivers waited for passengers, Racal loudly accused Francisco of being a traitor. Francisco, who was eating at the time, confronted Racal. Without warning, Racal stabbed Francisco multiple times, causing his immediate death. Racal fled the scene afterward. Racal did not deny stabbing Francisco but asserted he was insane and incapable of criminal intent during the act.
Trial Court Findings and Decision
The Regional Trial Court (RTC) of Cebu City found Racal guilty beyond reasonable doubt of murder and sentenced him to reclusion perpetua. It rejected the defense of insanity, determining Racal’s mental condition did not meet the legal definition of insanity exempting him from criminal liability. The court recognized treachery but ruled out evident premeditation as an aggravating circumstance. The RTC also ordered Racal to pay actual, moral, and civil damages to the victim’s heirs.
Court of Appeals’ Affirmation and Modification
The Court of Appeals (CA) affirmed the conviction and sentence but modified the award of damages to include six percent interest from the date of finality until full payment. The CA upheld the presence of treachery but agreed with the RTC that evident premeditation was not proven. The CA also concluded Racal failed to rebut the presumption of sanity, although it acknowledged a mitigating circumstance analogous to illness that diminished his willpower.
Legal Standards for Murder and Treachery
Murder under Article 248 of the RPC requires: (1) the killing of a person; (2) commission of the killing by the accused; (3) attendance of qualifying circumstances such as treachery or evident premeditation; and (4) the crime must not be parricide or infanticide. Treachery involves a deliberate, sudden, and unexpected attack that ensures execution of the offense without risk to the offender, leaving the victim no opportunity to defend or escape. Two elements must co-exist: the victim’s inability to defend himself at the moment of attack, and the accused’s intentional employment of the means to ensure execution.
Assessment of the Insanity Defense
The defense failed to overcome the presumption of sanity that the accused was of sound mind at the time of the crime. Insanity under Article 12(1) of the RPC requires complete deprivation of reason or intelligence at the time of the act, rendering the accused incapable of forming criminal intent. The psychiatric evaluations presented were conducted three to four years after the incident and thus could not reliably reflect Racal’s mental state during the offense. Furthermore, the experts’ findings indicated diminished capacity rather than total incapacity to discern right from wrong, which does not meet the strict standard for insanity. Additionally, Racal’s conduct such as fleeing immediately after the stabbing evidences conscious awareness and ability to control his actions, inconsistent with insanity.
Rejection of Evident Premeditation and Mitigating Circumstances
Evident premeditation requires proof of time and opportunity for reflection sufficient to allow the offender to reconsider the act before execution. There was no evidence of prior planning or a lapse of time between determination and execution of the crime. The court also rejected mitigating circumstances claimed by Racal, such as sufficient provocation and voluntary confession. Provocation was neither immediate nor sufficient in gravity, as insults occurred days earlier and calling someone “gay” was deemed not adequate provocation. Likewise, Racal’s “confession” was not spontaneous but introduced to support his insanity defense, thus failing as a mitigating factor.
Imposition of Penalty and Civil Liabilities
Reclusion perpetua was appropriately imposed as the penalty for murder qualified by treachery, consistent with Article
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Background and Antecedents
- Accused-appellant Roger Racal @ Rambo (hereinafter "Racal") was charged with murder under Article 248 of the Revised Penal Code (RPC), as amended, for fatally stabbing victim Jose "Joe" Francisco on April 19, 2006, at around 4:20 a.m. in Cebu City.
- The Information alleged that Racal, armed with a knife, acted with deliberate intent, treachery, and evident premeditation.
- Racal pleaded not guilty and raised the defense of insanity, supported by expert testimony claiming he had a predisposition to involuntary, uncontrollable mental episodes impairing his capacity to discern right from wrong.
- The Regional Trial Court (RTC) of Cebu City found Racal guilty beyond reasonable doubt, sentencing him to reclusion perpetua and ordering payment of actual, civil indemnity, and moral damages to the victim’s heirs.
- The RTC dismissed Racal's defense of insanity, determining his mental condition did not meet the legal standard to exempt him from criminal liability.
- On appeal, the Court of Appeals (CA) affirmed the conviction but modified the damages award to include interest from the finality of the decision.
- Racal filed a further appeal to the Supreme Court (SC), reiterating his insanity defense and alleging failure of the lower courts to appreciate mitigating circumstances of sufficient provocation and voluntary confession.
Factual Findings and Trial Proceedings
- Eyewitness testimonies established the following sequence of events:
- Around 4:00 a.m., several “trisikad” drivers—including victim Francisco—were waiting for passengers along Lopez Street in Cebu City.
- Racal was also present and loudly accused Francisco of being a traitor.
- Francisco responded by questioning Racal’s accusation while holding a plastic container and bread, indicating he was eating.
- Without warning, Racal approached Francisco and stabbed him multiple times in the chest and other parts of the body.
- Francisco collapsed and died at the scene before barangay tanods arrived.
- Racal immediately fled, hailed a trisikad from a dark portion of the street, and evaded arrest.
- Racal admitted stabbing Francisco but claimed insanity at the time of the crime.
- The RTC found the presence of treachery but excluded evident premeditation as an aggravating circumstance.
- Defense psychiatric evaluations occurred years after the incident and were deemed insufficient to prove insanity at the time of the crime.
- Testimonies showed Racal assumed caretaking responsibilities for his sister's children around the time of the killing, evidence inconsistent with an insane mind.
Issue on Murder and Legal Elements
- The essential elements of murder under Article 248 RPC, as upheld by the RTC and CA, were established:
- Death of the victim was caused by stabbing.
- Accused was the perpetrator of the killing.
- The killing was attended by the qualifying circumstance of treachery.
- The crime was not parricide or infanticid