People vs. Domingo G.R. No. 184343, March 2, 2009
Digested Case in Criminal Law
Murder and Frustrated Murder, Exemption of Criminal Liability in View of Insanity
Facts:
Appellant Jesus Domingo assails the Decision of the Court of Appeals dated 30 April 2008 in CA-G.R. CR No. 30511, modifying the Decision dated 13 November 2006 of Branch 13 of the Regional Trial Court (RTC) of Malolos, Bulacan. The Court of Appeals found appellant guilty beyond reasonable doubt of murder in Criminal Cases No. 1496-M-2000 and No. 1497-M-2000, attempted murder in Criminal Cases No. 1498-M-2000 and No. 1501-M-2000, frustrated murder in Criminal Case No. 1500-M-2000, and frustrated homicide in Criminal Case No. 1499-M-2000.
The testimony of the principal witness of the prosecution, Raquel Indon, is assailed by appellant for not being credible due to an inconsistency in her testimony and a lack of conformity with the experience of ordinary men.
Appellant also asserts that he was insane or completely deprived of intelligence during the commission of the alleged crimes, and therefore should be exempted from criminal liability in accordance with Article 12, Chapter 2 of the Revised Penal Code.
Issue:
Are appellant’s contention meritorious?
Ruling:
No.
First contention. Appellant refers to Raquel’s testimony during cross-examination wherein she narrated that after the appellant entered her bedroom, she screamed. Her sister-in-law, who lived next door, responded by asking Raquel who her assailant was, and the latter identified the appellant. Appellant claims that the conversation between Raquel and her sister-in-law was contrary to the ordinary course of things, and that the initial reaction of people in such a situation would be to ask for help from other people in order to save those who are in danger. Secondly, Raquel also testified during cross-examination that the appellant stabbed the front of her legs when she fell down. It is also argued that the appellant could not have stabbed the front of her legs, since she would be lying on front of her legs when she fell down.
This Court finds no merit in these arguments. To begin with, there was nothing out of the ordinary as regards Raquel’s testimony on these two matters. First, there was nothing unusual about the sister-in-law’s query as to who was attacking Raquel. Considering that the exchange merely consisted of this question and the reply to it, it would not even be accurate to refer to it as a "conversation." Secondly, it was not impossible for the appellant to stab the front of Raquel’s legs, had her legs been positioned sideways when she fell. But more importantly, these are peripheral details that do not affect the substantial aspects of the incident. Raquel clearly and positively testified that she was carrying her son Marvin when she rushed to the gate and fell down, and the appellant stabbed her legs and thereafter proceeded to stab Marvin who later died from the stab wounds. Her testimony was supported by the Medico-Legal Reports marked as Exhibits "E" and "F." Any inconsistencies in such peripheral details would not exculpate the appellant.
Second contention. His claim is not supported by evidence. Appellant offers his uncorroborated testimony as the only proof that he was insane at the time he committed the crime. He testified that nine days before he committed the crime, he suffered from lack of appetite, sleeplessness, and anxiety. In addition, he allegedly heard voices ordering him to kill bad people. He claims that he does not remember anything that happened on 29 March 2000, when the crimes were committed, and that he was already detained when he became conscious of his surroundings.
The law presumes every man to be of sound mind. Otherwise stated, the law presumes that all acts are voluntary, and that it is improper to presume that acts are done unconsciously. Thus, a person accused of a crime who pleads the exempting circumstance of insanity has the burden of proving beyond reasonable doubt that he or she was insane immediately before or at the moment the crime was committed.
Insanity exists when there is a complete deprivation of intelligence while committing the act; i.e., when the accused is deprived of reason, he acts without the least discernment because there is a complete absence of power to discern, or there is total deprivation of freedom of the will. Mere abnormality of the mental faculties is not enough, especially if the offender has not lost consciousness of his acts. Insanity is evinced by a deranged and perverted condition of the mental faculties and is manifested in language and conduct. An insane person has no full and clear understanding of the nature and consequences of his or her acts.
Even assuming that appellant’s testimony is credible, his sleeplessness, lack of appetite, nervousness and his hearing imaginary voices, while suggestive of an abnormal mental condition, cannot be equated with a total deprivation of will or an absence of the power to discern. Mere abnormality of mental faculties will not exclude imputability. The popular conception of the word "crazy" is used to describe a person or an act unnatural or out of ordinary. Testimony that a person acted in a crazy or deranged manner days before the commission of the crime does not conclusively prove that he is legally insane and will not grant him or her absolution.