People v. Valledor
REITERATIONFacts
The Antecedents: Accused-appellant Enrico A. Valledor was charged with murder, attempted murder, and frustrated murder for incidents that occurred on March 6, 1991. The informations alleged that he stabbed Elsa Villon Rodriguez, causing her death; stabbed Ricardo Maglalang, commencing the commission of murder but prevented by timely medical assistance; and stabbed Roger Cabiguen, performing all acts of execution for murder but saved by medical attendance. Accused-appellant was intermittently confined at the National Center for Mental Health and was arraigned only on February 19, 1993. He pleaded not guilty and the cases were archived until he was declared mentally fit to stand trial on November 15, 1994. Upon arraignment, he admitted the commission of the crimes but invoked insanity as an exempting circumstance. Procedural History: The Regional Trial Court of Palawan and Puerto Princesa City, Branch 47, convicted accused-appellant of murder, attempted murder, and frustrated murder. The dispositive portion of the RTC decision found him guilty beyond reasonable doubt of murder in Criminal Case No. 9359, frustrated murder in Criminal Case No. 9489, and attempted murder in Criminal Case No. 9401. He was sentenced to suffer reclusion perpetua for murder and frustrated murder, and imprisonment for attempted murder. His sentence was suspended, and he was ordered confined at the National Center for Mental Health until he became fit for service of sentence. The Petition: Accused-appellant appealed the RTC decision, raising the sole assignment of error that the lower court erred in convicting him despite his alleged mental illness at the time of the commission of the offense.
Issue(s)
Whether accused-appellant was legally insane at the time of the commission of the crimes. Whether the conviction for frustrated murder should be modified to attempted murder.
Ruling
The Supreme Court modified the decision of the Regional Trial Court. It affirmed the conviction for murder and attempted murder but modified the conviction for frustrated murder to attempted murder. The Court ordered the accused-appellant to serve his sentence successively. The award for actual damages and loss of income to Roger Cabiguen was deleted and replaced with temperate damages. Additional moral and actual damages were awarded to the heirs of Elsa Rodriguez.
Ratio Decidendi
On the issue of insanity: The Supreme Court held that the defense of insanity must be proven by clear and positive evidence, and the evidence must refer to the time preceding or at the moment of the commission of the crime. The law presumes all persons to be of sound mind, and it is improper to presume that acts were done unconsciously. The Court found that the accused-appellant failed to discharge the burden of overcoming the presumption of sanity. The Court pointed to several acts of the accused-appellant that demonstrated awareness and control, such as choosing specific victims, calling out Roger's nickname before stabbing him, leaving Simplicio and Antonio unharmed, uttering words of revenge after stabbing Elsa, and fleeing the scene. These acts were deemed inconsistent with a complete absence of the power to discern. The Court also noted that acts prior to the stabbing incident, such as crying, swimming with clothes on, and jumping off a jeepney, were not sufficient to prove legal insanity at the time of the commission of the crime. Similarly, medical findings of mental disorder after the commission of the crime have no bearing on his liability. On the modification of frustrated murder to attempted murder: The Supreme Court ruled that in Criminal Case No. 9489, accused-appellant should be held liable only for attempted murder and not frustrated murder. The Court reasoned that the wound sustained by Roger Cabiguen on his right forearm was not fatal. The settled rule is that where the wound inflicted on the victim is not sufficient to cause his death, the crime is only attempted murder, since the accused did not perform all the acts of execution that would have brought about death. Pursuant to Article 51 of the Revised Penal Code, the penalty for attempted crime is lower by two degrees than that prescribed for the consummated felony. The Court recalculated the penalty for attempted murder accordingly.
Main Doctrine
The defense of insanity must be proven by clear and positive evidence, and the evidence must refer to the time preceding or at the moment of the commission of the crime. Acts prior to the commission of the crime, or medical findings after the commission, are not sufficient to prove legal insanity at the time of the offense. Furthermore, the Supreme Court modified the conviction for frustrated murder to attempted murder, holding that where the wound inflicted is not sufficient to cause death, the crime is only attempted murder.