People v. Robiños
REITERATIONFacts
The Antecedents: The accused, Melecio Robiños, allegedly stabbed his wife, Lorenza Robiños, who was six months pregnant, causing her instantaneous death and the death of the fetus. The incident occurred on March 25, 1995, at around 7:00 a.m. in Brgy. San Isidro, Camiling, Tarlac. Procedural History: The Regional Trial Court (RTC) of Camiling, Tarlac, found Melecio Robiños guilty beyond reasonable doubt of the complex crime of parricide with unintentional abortion and sentenced him to suffer the penalty of death. The case was automatically elevated to the Supreme Court for review. The Petition: The accused appealed his conviction, primarily asserting the defense of insanity and arguing that the RTC erred in disregarding his psychiatric evaluation and defense of insanity.
Issue(s)
Whether the accused-appellant was suffering from insanity at the time of the commission of the crime, exempting him from criminal liability. Whether the RTC erred in imposing the death penalty without considering the presence or absence of aggravating and mitigating circumstances.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for the complex crime of parricide with unintentional abortion but modified the penalty. The Court ruled that the RTC erred in imposing the death penalty and reduced it to reclusion perpetua. The accused-appellant was ordered to pay P50,000.00 as civil indemnity and P22,800.00 as actual damages.
Ratio Decidendi
On the Issue of Insanity: The Court held that the defense of insanity was unsubstantiated and wanting in material proof. The presumption of law favors sanity, and the burden of proving insanity rests on the accused. The testimonies presented did not show a complete deprivation of reason or discernment at the time of the commission of the crime. Evidence of alleged insanity after the commission of the crime, or during detention, is insufficient to establish the defense. The psychiatrist's testimony was considered conjectural and inconclusive as it was made six months after the crime and lacked a proper background study of the accused's mental condition prior to the killing. The accused's admission of guilt and his actions immediately after the stabbing were inconsistent with a claim of insanity. On the Imposition of the Death Penalty: The Court found that the RTC erred in imposing the death penalty without considering the rules on the application of penalties. For the complex crime of parricide with unintentional abortion, the penalty for the graver offense, parricide, should be imposed. Parricide, as amended by RA 7659, is punishable with reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the lesser penalty, reclusion perpetua, must be applied, as mandated by Article 63 of the Revised Penal Code. The Court noted that the Office of the Solicitor General conceded this error.
Main Doctrine
Where the law prescribes a penalty consisting of two indivisible penalties, the lesser one shall be applied in the absence of any aggravating circumstances. The imposable penalty for parricide with unintentional abortion, in the absence of aggravating circumstances, is reclusion perpetua, not death.