FACTS:
Dominga Agnas Vda. De Globo, a seventy-three year old woman, was allegedly chased by accused-appellant Roland Miraña, with a bolo.
After the incident, Dominga’s brother advised her not to go back to her house and to report the incident to the barangay. Unfortunately, the victim did not heed the advice and returned to her house.
Between 6 o’clock to 6:30 in the morning of 17 June 2008, Armando, Dominga’s neighbor, was at the coconut plantation near his house when he heard a woman cry out followed by a loud cry of a man. Believing that the sounds emanated from his house, Armando immediately ran in that direction. As he came near his house, he saw a woman lying on her side on the ground in front of the door to his house. Armando recognized the woman as Dominga. He also saw accused-appellant’s father crying at the back of their house facing the accused-appellant.
PO3 Bobby Corono and two other police officers, responded to a call about the incident. Accused-appellant approached PO3 Corono and admitted he was responsible for Dominga’s death. He then pointed to a bolo and said that he used it to hack the victim and washed it afterward. PO3 Corono thereafter arrested accused-appellant and brought him to the police station along with the bolo as evidence.
Accused-appellant admitted to Dominga’s son that he killed her.
Accused-appellant was initially charged with homicide butthe information for homicide was withdrawn, and the Office of the Provincial Prosecutor ordered that a new information for murder be filed against accused-appellant.
On 20 June 2008, an order for the immediate transfer of the accused to the Bicol Medical Center Mental Hospital was issued based on the report that he was being violent to himself and to others at the jail.
On the other hand, Imelda Miraña found out that her son, accused-appellant, had killed the victim. She allegedly noticed that her son started exhibiting odd behavior after his nose was bitten by a cousin. Accused-appellant would smile without anyone in front of him; he would call a chicken late at night; and would keep on saying to himself that Dominga was a witch.
During trial, accused-appellant claimed not to know or recal1 the events surrounding the incident, the identity of the victim, and his confinement and treatment at the mental hospital.
The RTC ruled that accused-appellant was not able to prove his defense of insanity, holding that “while the purported behavior of accused-appellant would suggest an abnormal mental condition, it cannot however be equated with a total deprivation of will or an absence of the power to discern, to accept insanity.” The RTC appreciated the aggravating circumstance of abuse of superior strength to qualify the crime to murder.
On appeal, the CA agreed with the RTC that accused-appellant failed to overcome the presumption of sanity; and his bizarre acts prior to the incident cannot be considered insanity for the purpose of exonerating him because not every aberration of the mind constitutes insanity.
ISSUE:
WHETHER OR NOT INSANITY COULD BE APPRECIATED IN ACCUSED-APPELLANT’S FAVOR IN ORDER TO EXCULPATE HIM FROM CRIMINAL LIABILITY.
RULING:
The Court finds no reason to disturb the judgment of the CA in the matter of accused-appellant’s insanity, but finds that he should only be liable for homicide.
The defense failed to prove accused-appellant’s insanity at the time of the commission of the crime.
The defense of insanity is in the nature of a confession or avoidance because an accused invoking it admits to have committed the crime but claims that he should not be criminally liable therefor because of insanity, which is an exempting circumstance.
Consequently, the accused is tried on the issue of sanity alone, and if found to be sane, a judgment of conviction is rendered without any trial on the issue of guilt.
However, an accused invoking the exempting circumstance of insanity bears the burden of proving it with clear and convincing evidence because every person is presumed sane.
For the defense of insanity to prosper, it must be proven that the accused was completely deprived of intelligence, which must relate to the time immediately preceding or simultaneous to the commission of the offense with which he is charged.
Since the state of a person’s mind can only be judged by his behaviour, establishing the insanity of an accused requires opinion testimony which may be given by a witness who is intimately acquainted with the accused, or who has rational basis to conclude that the accused was insane based on the witness’ own perception of the accused, or who is qualified as an expert, such as a psychiatrist.
Taken against the standard of clear and convincing evidence, the proof proffered by the defense fails to pass muster.
Moreover, unusual behaviors such as smiling to oneself and calling a chicken late at night are not proof of a complete absence of intelligence, because not every aberration of the mind or mental deficiency constitutes insanity.
The Court has held that “the prevalent meaning of the word ‘crazy’ is not synonymous with the legal terms ‘insane,’ ‘non compos mentis,’ ‘unsound mind,’ ‘idiot,’ or ‘lunatic.’
The popular conception of the word ‘crazy’ is being used to describe a person or an act unnatural or out of the ordinary. A man may behave in a crazy manner but it does not necessarily and conclusively prove that he is legally so.”
In order to be exempt from criminal liability, the accused must be so insane as to be incapable of criminal intent
It is clear from the foregoing circumstances that the defense failed to prove accused-appellant’s insanity at the time of the commission of the crime with the requisite quantum of proof. Consequently, accused-appellant’s conviction must be upheld.
Abuse of superior strength cannot be appreciated, such that accused-appellant can only be held liable for homicide, not murder.
This Court finds that the conviction of the accused-appellant for murder is flawed because of the erroneous appreciation of abuse of superior strength as a qualifying circumstance. The Court finds that the presence of this circumstance in the commission of the crime was not sufficiently proven.
Dominga Agnas Vda. De Globo, a seventy-three year old woman, has been living with her cousin Alberto after being allegedly chased by accused-appellant with a bolo. Alberto invited her to sleep in his house and advised her to report the incident to the barangay. The victim, however, rejected the idea because accused-appellant was her relative.
Thereafter, the victim left Alberto’s house and proceeded to her brother’s house. After relating the incident to her brother, she was once again advised not to go back to her house and to report the incident to the barangay. Unfortunately, the victim did not heed the advice. She then returned to her house to await the call of her son, who was working abroad.
Accused-appellant entered a plea of guilty. In view of accused-appellant’s admission that he caused the victim’s death, a reverse trial ensued.