People v. Aldemita
REITERATIONFacts
The Antecedents: The accused, Renato Aldemita y Malihan, was charged with murder and frustrated murder. The deceased victim, Erlinda Viardo, was the managing partner of an accounting firm, and Angelita Yambao was her secretary. Aldemita was an employee of the same firm. On March 5, 1976, Aldemita entered Viardo's office, locked the door, and attacked Yambao with a jungle bolo, wounding her. He then proceeded to attack Viardo, inflicting multiple fatal wounds. Yambao managed to escape and seek help. Another employee and the driver witnessed parts of the incident. Aldemita eventually surrendered to the police. Post-mortem examination revealed numerous incised and stab wounds on Viardo. Yambao sustained lacerations and abrasions. Procedural History: Aldemita was found guilty beyond reasonable doubt of murder and frustrated murder by the former Circuit Criminal Court of Manila. He was sentenced to death for murder and an indeterminate penalty for frustrated murder. The case was elevated to the Supreme Court on automatic review due to the death penalty. The Petition: Aldemita did not deny committing the acts but claimed he was insane at the time, thus seeking exemption from criminal liability. His defense was anchored on psychiatric reports from the National Mental Hospital, expert testimonies, and his wife's testimony regarding his disturbed state.
Issue(s)
Whether the accused was insane at the time of the commission of the crimes of murder and frustrated murder. Whether the aggravating circumstances of abuse of superior strength, evident premeditation, disregard of respect due the offended party on account of her rank, and cruelty were attendant to the crime of murder. Whether the aggravating circumstance of abuse of superior strength was attendant to the crime of frustrated murder. Whether the civil indemnity and damages awarded by the trial court were proper.
Ruling
The Supreme Court affirmed the judgment of the trial court with modifications. The civil indemnity for murder was increased, and the death penalty was reduced to reclusion perpetua. The conviction for frustrated murder and the associated penalties and damages were affirmed. The defense of insanity was rejected.
Ratio Decidendi
On the issue of insanity: The Court reiterated the legal presumption that all persons are of sound mind and that acts are voluntary. Insanity, as an exception, must be proven by the defense with clear and positive evidence. The inquiry into mental condition must relate to the time of the commission of the offense. The Court found that Aldemita's actions immediately before, during, and after the commission of the crimes demonstrated a clear possession of his mental faculties. These included playing chess, checking the log book for his assignment, craftily wrapping his weapon, locking the door to prevent succor, resisting intervention, surrendering peacefully after assurance, and declining to give a statement without a lawyer. These acts were deemed inconsistent with a complete deprivation of intelligence or will, characteristic of legal insanity. The Court noted that schizophrenia, while a mental disorder, does not necessarily equate to a complete deprivation of intelligence or the power to discern, as required for legal insanity. The Court cited People vs. Puno where a similar defense of schizophrenia was rejected despite more erratic behavior. On the aggravating circumstances for murder: The Court found that treachery qualified the crime to murder. The aggravating circumstances of abuse of superior strength, evident premeditation, disregard of respect due the offended party on account of her rank, and cruelty were also found to be present and were not offset by any mitigating circumstances. The Court noted that Aldemita's actions, such as the planned attack and the manner of inflicting wounds, supported these aggravating circumstances. On the aggravating circumstance for frustrated murder: The Court found that treachery qualified the crime to frustrated murder, and the aggravating circumstance of abuse of superior strength was also attendant, with no mitigating circumstances present. On the civil indemnity and damages: The Court modified the civil indemnity for murder, increasing it from P12,000.00 to P30,000.00, in line with prevailing jurisprudence. The other damages awarded by the trial court were maintained as they were correctly computed based on the evidence.
Main Doctrine
The defense of insanity requires proof of complete deprivation of intelligence or will at the time of the commission of the offense. Mere abnormality of mental faculties or a diagnosis of schizophrenia does not automatically exclude criminal liability if the accused acted with discernment and awareness of his actions.