Case Summary (G.R. No. 216453)
Trial Court Ruling
The Regional Trial Court of Olongapo City found petitioner guilty beyond reasonable doubt of Carnapping under RA No. 6539, as amended. All elements—unlawful taking, intent to gain, lack of consent—were established. The court rejected the insanity defense, deeming Dr. Evangelista’s single evaluation inconclusive. Petitioner was sentenced to an indeterminate term of fourteen years and eight months minimum to seventeen years and four months maximum.
Court of Appeals Ruling
On appeal, the Court of Appeals affirmed. It held that petitioner’s lone psychiatric evaluation failed to prove complete deprivation of reason or will at the time of the offense. No evidence of abnormal behavior immediately before or during the carnapping was presented. The CA denied the motion for reconsideration, leading to this petition.
Issue on Insanity Defense
Petitioner contends that psychosis deprived him of voluntariness and free will, warranting exemption or, at minimum, mitigation under RPC Articles 12 and 13. He argues reliance on People v. Rafanan and People v. Antonio to support mitigation.
Legal Framework on Insanity
Under Article 12(1) of the Revised Penal Code, an insane person is exempt from liability if deprived of reason or will at the time of the act. The accused bears the burden to prove insanity with clear and convincing evidence, focusing on the immediate period before or during the offense. Expert or lay opinion testimony must demonstrate total absence of discernment.
Supreme Court Analysis on Insanity
The Supreme Court found petitioner’s evidence insufficient. Dr. Evangelista saw him only once and could not identify the specific psychosis or confirm its presence at the time of the crime. No witness described abnormal conduct contemporaneous with the carnapping. Petitioner’s admission of the act meant the trial addressed sanity alone; having failed to prove insanity, conviction was proper.
Mitigating Circumstance Under Special Law
Petitioner’s claim for mitigation under Article 13(9) of the RPC is inapplicable to RA No. 6539
...continue readingCase Syllabus (G.R. No. 216453)
Facts of the Carnapping Incident
- On November 20, 2007 at approximately 3:45 PM in Olongapo City, Gregorio Calimag parked his 1996 Honda CRV (Plate No. RFC-269) across Mulawain Bakery, leaving the key inside.
- Two minutes later, he observed the vehicle moving without his consent toward Peping Mami along Caron Street.
- Gregorio flagged down and boarded a tricycle to pursue the moving vehicle, shouting that it was being carnapped and belonged to him.
- The stolen CRV was eventually intercepted in a traffic jam at Brill Street corner 20th Street, where Gregorio seized the driver—later identified as Oligario Turalba y Villegas—and instructed the tricycle driver to summon the police.
- PO2 Reychard V. Valencia and SPO4 Danilo CaAutal arrived on the scene at around 3:50 PM, took custody of Oligario, advised him of his rights, and recovered a seven-inch butterfly knife from his person.
- Both Oligario and Gregorio were brought to the police station for investigation; the vehicle was recovered intact.
Charge and Lower Courts’ Findings
- Oligario was charged with Carnapping under Republic Act No. 6539, as amended, for taking a motor vehicle with intent to gain and without the owner’s consent.
- He pleaded “not guilty” at his arraignment, prompting trial on the merits.
- The Regional Trial Court (Branch 75, Olongapo City) found all elements of Carnapping proven beyond reasonable doubt:
- Unlawful and felonious taking of the vehicle
- Absence of owner’s consent
- Intent to gain
- The trial court gave full credence to prosecution witnesses and rejected Oligario’s insanity defense as inconclusive.
Defense of Insanity
- Oligario’s sole defense was insanity, premised on psychosis due to alcohol and methamphetamine use.
- Dr. Ma. Lourdes Labarcon Evangelista testified she first evaluated him on October 24, 2007 at Mariveles Mental Hospital, diagnosing psychosis and prescribing medication.
- Dr. Evangelista conceded she saw Oligario only once and could not identify the specific type or degree of psychosis.
RTC Decision and Reasoning
- In its December 6, 2012 decision, the RTC convicted Oligario of Carnapping and imposed an indeterminate sentence of 14 years and 8 months to 17 y