G.R. No. 216021 - Verdadero y Galera vs. People

Case Summary (G.R. No. 216021)

Factual Background

On March 12, 2009, after a reported theft of a fan belt, Romeo B. Plata and his son Maynard went to the Baggao Police Station where an encounter with the petitioner occurred; later, while Maynard stopped at a drugstore and Romeo walked toward a nearby store, Maynard heard shouts and saw Verdadero stab Romeo repeatedly with a Rambo knife. Romeo was brought to the Cagayan Valley Medical Center where he was pronounced dead; the post-mortem reported cardiopulmonary arrest secondary to severe hemorrhage due to multiple stab and hack wounds.

Evidence of the Prosecution

The prosecution relied principally on eyewitness testimony from Maynard Plata and Ronnie Elaydo who recounted the report of the alleged theft, the confrontation at the police station, and the stabbing observed by Maynard at the drugstore; police officers arrested Verdadero at the scene; the post-mortem report established the fatality and cause of death consistent with multiple stab wounds.

Evidence of the Defense

The defense presented evidence that Verdadero suffered from a longstanding psychiatric disorder. He had been an outpatient at the Cagayan Valley Medical Center psychiatric department since 1999, was diagnosed with depression in 2001 and schizophrenia on July 21, 2003, had multiple confinements including a confinement in 2009, and displayed intermittent violent behavior. Family testimony described prior violent episodes and an episode on March 12, 2009, after which Verdadero was sedated and isolated at the hospital. Dr. Ethel Maureen Pagaddu conducted a court-ordered mental examination and testified that Verdadero had suffered a relapse of schizophrenia around the time of the stabbing and that relapse could affect impulse control and judgment, although she hesitated to categorically rule out a lucid interval given medication.

Trial Court Proceedings

The Regional Trial Court found Verdadero guilty beyond reasonable doubt of the felony of Homicide, under Article 249, Revised Penal Code, and sentenced him to an indeterminate prison term specified in the judgment and ordered payment of P50,000.00 as death indemnity, P50,000.00 as moral damages, and P30,000.00 as stipulated actual damages. The RTC declined to accept the defense of insanity, ruling that Verdadero failed to prove he was not in a lucid interval or completely of unsound mind at the time of the killing, and found that the elements of treachery and evident premeditation had not been established to elevate the crime to murder.

Court of Appeals Proceedings

The Court of Appeals affirmed the RTC in its July 10, 2014 Decision, agreeing that although Verdadero had a history of schizophrenia, the defense did not establish by clear and convincing evidence that he was not in a lucid interval at the time of the stabbing; a motion for reconsideration filed by Verdadero was denied in a December 15, 2014 resolution.

Issues Presented

The sole substantive issue pressed before the Supreme Court was whether the Court of Appeals gravely erred in affirming Verdadero’s conviction despite, as the petitioner contended, clear and convincing evidence of his insanity at the time of the incident.

Parties' Contentions

Verdadero contended that his psychiatric history and expert testimony, together with eyewitness observations, established that he was in relapse and not of sound mind at the time he stabbed Romeo, thus exempting him from criminal liability. The Office of the Solicitor General maintained that the petition principally raised a question of fact that was not proper under Rule 45, Rules of Court, and argued that the evidence failed to establish insanity at the time of the offense.

Rule 45 and Exceptions

The Court acknowledged the general rule that Rule 45 permits review only of questions of law, but reiterated the established exceptions articulated in Laborte v. Pagsanjan Tourism Consumers' Cooperative et al., which permit factual re-examination when findings are grounded entirely on speculation, when inferences are manifestly mistaken or impossible, when there is grave abuse of discretion, when judgments are based on misappreciation of facts, when findings conflict or contradict admissions or are conclusions without citation of specific evidence, and related circumstances; the Court concluded that the circumstances of this case warranted application of those exceptions to resolve the factual question of Verdadero’s mental state at the time of the stabbing.

Legal Standard for Insanity

The Court reiterated the governing standard under Article 12, Revised Penal Code and its jurisprudence: insanity as an exempting circumstance exists only when there is a complete deprivation of intelligence or freedom of will at the time of the act, the burden of proof rested upon the accused, and such defense must be proven by clear and convincing evidence. The Court emphasized that the incapacity must be manifest at the time of or immediately before the commission of the offense and that proof of mental disorder before or after the act may be material if it tends to show the accused’s mental condition at the critical time.

Court's Factual Findings and Reasoning

Applying the standards, the Court found that Verdadero had established by clear and convincing evidence that he suffered a relapse of schizophrenia at the time of the stabbing. The Court stated that direct proof of mental state at the exact moment was not necessary where competent circumstantial evidence existed immediately before and after the incident. It gave considerable weight to the expert testimony of Dr. Pagaddu, who diagnosed relapse and explained that relapse could impair impulse control and judgment and made possible an inability to distinguish right from wrong. The Court also relied

Case Syllabus (G.R. No. 216021)

Parties and Posture

Solomon Verdadero y Galera filed a petition for review on certiorari under Rule 45 challenging the conviction affirmed by the Court of Appeals.
People of the Philippines prosecuted Verdadero for killing Romeo B. Plata by an Information filed on September 9, 2009.
Verdadero was arraigned on June 3, 2011 and pleaded not guilty before the Regional Trial Court.
Verdadero invoked the defense of insanity during pre-trial and proceeded to trial without a reverse trial.
The Regional Trial Court, Branch 03, Tuguegarao City, rendered judgment on May 30, 2013 convicting Verdadero of homicide under Article 249, Revised Penal Code.
The Court of Appeals affirmed the conviction in a July 10, 2014 Decision and denied reconsideration on December 15, 2014.
Verdadero elevated the case to the Supreme Court raising primarily the single issue of whether his insanity at the time of the killing was established by clear and convincing evidence.

Key Facts

On March 12, 2009 at about 3:00 p.m., Solomon Verdadero y Galera allegedly stabbed Romeo B. Plata with a Rambo knife in Barangay Baggao, Cagayan.
Romeo and his son Maynard went to the Baggao Police Station to report a stolen fan belt and later left by tricycle when the stabbing occurred near a drugstore.
Witness Ronnie Elaydo alerted Maynard to the attack and Maynard saw Verdadero stabbing Romeo on the left upper back and again below the right shoulder.
Verdadero allegedly attempted to attack Maynard, who defended himself with a small stool, while Ronnie ran to the police station to seek help.
Police arrested Verdadero at the scene and Romeo was brought to Cagayan Valley Medical Center where he died; the post-mortem cited cardiopulmonary arrest due to severe hemorrhage from multiple stab and hack wounds.
Verdadero had a long psychiatric history beginning in 1999 with diagnoses of depression and, on July 21, 2003, schizophrenia, and he had multiple psychiatric confinements and outpatient treatments prior to the incident.

Statutory Framework

The accused was charged under Article 249, Revised Penal Code which defines and penalizes homicide.
The defense invoked Article 12, Revised Penal Code which provides that an imbecile or insane person is exempt from criminal liability except during a lucid interval.
The petition to the Supreme Court was brought under Rule 45, Rules of Court, subject to the rule that only questions of law are ordinarily reviewable.

Issues Presented

Whether the Court of Appeals gravely erred in affirming Verdadero's conviction despite the claim that his insanity at the time of the incident was established by clear and convincing evidence.
Whether the Supreme Court may review the factual finding of the courts below under the recognized exceptions to Rule 45.

Contentions of the Parties

Verdadero contended that he suffered a relapse of schizophrenia at the time of the stabbing and that his mental state rendered him completely deprived of intelligence, thereby exempting him from criminal liability.
The Office of the Solicitor General argued that the petition primarily involved a question of fact not proper under Rule 45 and that the evidence did not fully establish the absence of a lucid interval at the time of the offense.

Evidence

The prosecution presented eyewitness testimony from Maynard Plata and Ronnie Elaydo describing the stabbing, the weapon, the victim's injuries, and Verdadero's arrest.
The post-mortem report established the cause of death as cardiopulmo