Title
People vs. Salvador, Sr. y Masayang
Case
G.R. No. 223566
Decision Date
Jun 27, 2018
Accused-appellant convicted of parricide and multiple murders; insanity defense rejected due to lack of evidence proving mental state during crime.
murder
reclusion perpetua
defense of insanity

Case Summary (G.R. No. 223566)

Informations and Charged Offenses

In Criminal Case No. 17628, accused-appellant was charged with killing Junie M. Salvador, Jr., his two-year-old child, through an armed assault with bolos, with intent to kill, and the information expressly alleged the element of killing that resulted in death and civil liability to the heirs.

In Criminal Case Nos. 17629 and 17630, accused-appellant was charged with the killing of Rosana B. Realo and Miraflor B. Realo, respectively, with allegations of being armed with bolos, intent to kill, and qualifying circumstances of treachery and evident premeditation.

In Criminal Case Nos. 17631 and 17632, accused-appellant was charged with the killing of Mariz R. Masayang and Jonessa R. Masayang (later identified in the records as Jannes), with similar allegations of intent to kill, use of bolos, and qualifying circumstances of treachery and evident premeditation.

Factual Background as Told by the Prosecution

The prosecution presented a narrative beginning on 11 February 2011. At about 6:00 a.m., accused-appellant and his live-in partner Miraflor, together with Miraflor’s daughter Melissa and Melissa’s husband Santos, were walking toward the barangay hall to attend the Pamilya Pantawid program. The prosecution evidence portrayed accused-appellant as initially behaving affably toward Miraflor, cracking jokes, and later telling Miraflor and Melissa that he would go home because his name did not appear in the program list.

At about 11:30 a.m. at the barangay hall, Melissa told Santos to go home so he could feed their children, Mariz and Jannes. When Santos could not find his children at home, he searched among neighbors’ houses and then saw accused-appellant on the street with blood on his arms and shirt and holding a bolo. Santos asked what happened, but accused-appellant did not reply. Santos returned to the barangay hall and reported that the children were missing and that accused-appellant had “gone wild.” Melissa later conveyed what Santos told her to Miraflor.

The prosecution also relied on the testimony of Joy, who testified that while she was on her way to Miraflor’s house to look for Mariz and Jannes, she saw accused-appellant chasing Miraflor in the street. Joy was about two arm-lengths away when accused-appellant, using a bolo, hacked Miraflor four times in the back and in the nape. Joy then saw accused-appellant drag Miraflor toward their house by pulling her hair.

Kagawad Salaysay and two soldiers proceeded to the house after learning of the incident and saw accused-appellant holding two bolos while Miraflor lay on the floor. When Salaysay told accused-appellant to surrender, accused-appellant voluntarily complied. He stated, “I will surrender Cons,” and, “If I want to kill a lot of people, I could but I only killed my family,” and thereafter handed his bolos to Salaysay’s companion. Only when policemen entered the house were the bodies discovered, including those of the four dead children—Mariz; Jannes; Rosana; and Dioney, Jr. (Miraflor’s son with accused-appellant).

The prosecution evidence further showed that at the Kapalong police station, Police Officer I Kim Aguspina asked accused-appellant about his personal circumstances and accused-appellant was responsive.

Defense Theory: Insanity and Lack of Recall

The defense presented a psychiatric account through Dr. Reagan Joseph Villanueva and testimony from accused-appellant. Dr. Villanueva testified that he reviewed the records of psychiatrist Dr. Giola Fe Dinglasan, who had examined accused-appellant on 6 June 2012, sixteen months after the 11 February 2011 incident. Dr. Dinglasan, according to Dr. Villanueva, diagnosed accused-appellant with a schizoaffective disorder, and initially provided medicine for depression and later for psychosis. Dr. Villanueva opined that relapse was possible if accused-appellant was not given medication.

Accused-appellant testified that he remembered who his victims were, but he claimed he did not recall that he killed them, nor did he recall the incident before their deaths or where he was on 11 February 2011. He asserted that only his sister informed him of the deaths. He also claimed a happy relationship with Miraflor and a close relationship with his son Dioney, Jr. He further claimed he had stopped taking prohibited drugs when he began living with Miraflor, and he gave up smoking while in prison. He denied ever being confined in a mental hospital before or after incarceration.

Trial Court Ruling (RTC)

The RTC found that there was no dispute that accused-appellant was the author of the killings of Miraflor and the four children. The RTC framed the controversy as whether accused-appellant was fully aware of the wrongness of his acts to establish criminal liability. It ruled that accused-appellant failed to prove insanity or loss or absence of reason by clear and convincing evidence.

The RTC also held that the killing of Dioney, Jr. fell within Article 246 of the RPC on parricide, since Dioney was accused-appellant’s son. With respect to the other victims—Miraflor, Rosana, Mariz, and Jannes—the RTC held that the hacking attacks were attended by the qualifying circumstance of treachery, particularly emphasizing that the minors could not have suspected the attack and could not defend themselves, consistent with the wounds found on the back, torso, and skull.

On penalty and damages, the RTC convicted accused-appellant for each death and sentenced him to reclusion perpetua for each case. It also ordered payments for wrongful death and moral damages in specified amounts in its dispositive portion.

Appellate Court Ruling (CA)

The CA affirmed the convictions but modified the award of damages to conform to jurisprudence. It reiterated that the principal issue was whether accused-appellant was mentally insane at the time of the killings, which would exempt him from criminal liability. The CA found that accused-appellant’s insanity defense failed because no evidence showed that he was struck with the disorder immediately prior to or during the hacking incident.

The CA observed that the disorder was diagnosed more than a year after the incident and that the defense position was speculative and inconclusive. The CA sustained the penalty imposed by the RTC, subject only to adjustments in damages.

Issues on Appeal

Accused-appellant raised two principal assignments of error: first, that the RTC and CA erred in not giving probative weight to Dr. Villanueva’s testimony and psychiatric evaluation finding that accused-appellant suffered from schizoaffective disorder; and second, that the trial court erred in convicting him despite the alleged failure of the prosecution to prove guilt beyond reasonable doubt.

Supreme Court’s Treatment of the Insanity Defense

The Supreme Court rejected the appeal. It agreed that the controlling dispute was whether accused-appellant was insane at the time he committed the offenses, noting that it was undisputed that he killed the victims and that the only crux was the mental state for exemption from criminal liability.

The Court reiterated the presumption of sanity and sound mental faculties, anchored on the principle reflected in Article 800 of the Civil Code, and it treated the plea of insanity as a defense in the nature of confession and avoidance. It then restated the legal standard under Article 12(1) of the RPC, explaining that insanity must involve a complete deprivation of intelligence, such that the accused acted without discernment and with total deprivation of freedom of the will.

The Court emphasized that the insanity plea is a factual matter requiring proof that relates to the time preceding or coetaneous with the commission of the crime. It stressed that the defense bears the burden of proving insanity and that two elements must concur: complete deprivation of intelligence, reason, or discernment; and existence of such insanity at the time of or immediately preceding the commission of the crime.

Evaluation of Psychiatric Evidence and Timing

In applying these standards, the Court found that the evidence did not establish insanity at the relevant time. It took note that Dr. Dinglasan’s initial evaluation was on 22 March 2011, more than a month after the incident, and the records lacked any showing of the diagnosis as of that date. The Court further noted that the certification showed a diagnosis only on 6 June 2012, and not earlier. Dr. Villanueva’s own personal examination was on 27 September 2012, which was one year and seven months after the killing. The Court found that the defense offered no documentary proof on how Dr. Villanueva arrived at the diagnosis, and it held that Dr. Villanueva’s testimony did not show specific observations about accused-appellant’s condition in relation to the killings.

The Court relied on Dr. Villanueva’s admission that the determination of the condition depended on observations made during consultations and that there was no exact way to state when the condition started. The Court held that the inability to ascertain the condition immediately preceding the killings rendered the diagnosis long after the incident insufficient to prove the mental state at the time of the offenses.

It also held that Dr. Villanueva conceded the possibility that the accused-appellant’s disorder might have been triggered by the massacre committed, rather than it existing at the time of the killings. The Court underscored that inquiry into mental state must relate to the period immediately before or at the moment the felony was committed, and it treated proof based primarily on later diagnosis as inadequate for the strict criterion for exemption.

Assessment of Accused-Appellant’s Testimony and Behavioral Oddities

The Supreme Court further evaluated accused-appellant’s testimony. It observed that while accused-appellant denied memory of what transpired, he admitted he knew who his victims were. The Court concluded that accused-appellant explained his lack of

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

About Privacy Terms