People v. Macalindong
REITERATIONFacts
The Antecedents: Appellant Leonardo Macalindong was charged with murder for the killing of his live-in partner, Jovelia Malinao. The prosecution alleged that on February 10, 2007, appellant, armed with a bladed instrument, attacked Jovelia with treachery, evident premeditation, and abuse of superior strength, inflicting multiple stab wounds that caused her instantaneous death. Procedural History: The Regional Trial Court (RTC) of Oriental Mindoro, Branch 40, found appellant guilty of murder, appreciating treachery but not evident premeditation. The RTC sentenced him to reclusion perpetua and awarded civil indemnity, moral damages, and exemplary damages. The Court of Appeals (CA) affirmed the conviction, adding abuse of superior strength as a qualifying circumstance, increasing damages, and imposing legal interest. The CA's decision was dated April 4, 2019. The Petition: The appellant appealed his conviction, arguing that the CA erred in appreciating treachery and in not giving credence to his defense of insanity due to schizophrenia. The Supreme Court reviewed the case.
Issue(s)
Whether the appellant can be credited with the exempting circumstance of insanity. Whether the appellant was properly convicted of murder, and if not, what crime was committed and what is the appropriate penalty and damages.
Ruling
The Supreme Court affirmed the conviction but modified it from murder to homicide. The Court ruled that the appellant's defense of insanity was unsubstantiated and that the killing was not attended by treachery or abuse of superior strength, thus reducing the crime to homicide. The dispositive portion sentenced appellant to eight (8) years of prision mayor, as minimum, to fourteen (14) years, eight (8) months, and one (1) day of reclusion temporal, as maximum, and ordered him to pay P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P50,000.00 as temperate damages, all subject to 6% legal interest per annum from finality of the decision until fully paid.
Ratio Decidendi
On the issue of insanity: The Court held that the defense of insanity requires a complete deprivation of intelligence, reason, or discernment at the time of the commission of the crime. Appellant's claim of having "blacked out" and his diagnosis of schizophrenia, supported by an initial report from the National Center for Mental Health (NCMH) and a medical certificate from Dr. Lindo, were deemed insufficient. The Court noted that Dr. Lindo was not presented to explain the medical certificate, and the NCMH report's specific time frame of illness was not elucidated. The Court reiterated that mere abnormality of mental faculties does not exclude imputability and that the proof of insanity must relate to the time preceding or coetaneous with the commission of the offense. Without clear and convincing evidence that appellant was deprived of reason or acted without discernment at the exact moment of the killing, the defense of insanity cannot be credited as an exempting circumstance. The Court cited jurisprudence emphasizing that the burden of proof rests on the accused to establish insanity beyond reasonable doubt. On the conviction for murder, the proper crime, and the imposable penalty and damages: The Court found that the killing of Jovelia was not attended by treachery or abuse of superior strength, thus negating the charge of murder. The suddenness of the attack during a quarrel did not equate to treachery, and the means adopted were not a deliberate result of a determination to ensure success in committing the crime. Abuse of superior strength was also ruled out as the act was impulsive and there was no proof of notorious inequality of forces or a conscious intent to take advantage of it. Since no qualifying circumstances were proven, the killing was classified as homicide. The Court gave credence to Lyn Joy's positive identification of her father as the perpetrator, and found that the intent to kill was sufficiently proven by the multiple stab wounds inflicted upon the victim. For homicide, the penalty is reclusion temporal. In the absence of mitigating or aggravating circumstances, the Court applied the Indeterminate Sentence Law, imposing a minimum of eight (8) years of prision mayor and a maximum of fourteen (14) years, eight (8) months, and one (1) day of reclusion temporal. The Court awarded P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P50,000.00 as temperate damages to the heirs of Jovelia. Exemplary damages were not awarded as there were no proven aggravating circumstances. The Court clarified that legal interest at 6% per annum should be applied from the finality of the judgment until full satisfaction, not from the filing of the information, as the damages awarded were unliquidated claims.
Main Doctrine
The defense of insanity requires a complete deprivation of intelligence, reason, or discernment at the time of the commission of the crime, and mere abnormality of mental faculties or a diagnosis of schizophrenia without proof of its manifestation at the time of the offense is insufficient to exempt from criminal liability. Furthermore, treachery and abuse of superior strength cannot be appreciated when the act was committed impulsively and on the spur of the moment, leading to a conviction for homicide instead of murder.