People vs. Roa

For insanity to exempt from criminal liability under Article 12(1) of the Revised Penal Code, the accused must prove by clear and convincing evidence that at the time immediately preceding or simultaneous with the commission of the offense, there was a complete deprivation of intelligence or freedom of will; evidence of mental illness at other periods, without proof of continuity linking it to the moment of the crime, is insufficient to overcome the presumption of sanity.

Sometime in 2000, Roa sustained a head injury after being struck by teenagers. Thereafter, his behavior changed markedly: from silent and formal, he became talkative, talked to himself, and complained of headaches. In 2001, he experienced a psychotic episode and was confined at the Don Susana J. Rodriguez Mental Hospital. He was subsequently diagnosed with schizophrenia at the Bicol Medical Center and received treatment until his discharge in 2002. Due to financial constraints, he discontinued antipsychotic medication after discharge.

In March 2007, during the wake of an aunt, Roa exhibited disturbed behavior—he neither slept nor ate, walked alone for long periods, refused to bathe, and quarreled with his mother. On the afternoon of March 16, 2007, at Barangay San Miguel, Bula, Camarines Sur, Roa attacked Eliseo Delmiguez with a bolo, stabbing him in the lower back from behind. Delmiguez died from multiple stab wounds. Roa was charged with murder qualified by treachery.

• Accused’s Mental Health History: Roa was struck on the head by teenagers in 2000, after which his personality transformed. In 2001, he had a psychotic episode and was confined at the Don Susana J. Rodriguez Mental Hospital. He was diagnosed with schizophrenia at the Bicol Medical Center and underwent treatment in 2001, 2002, 2003, 2004, and 2005, but was discharged in 2002. Financial difficulty prevented continued intake of antipsychotic medication. His uncle Isaac Mejaro testified that during the wake of an aunt in March 2007, Roa neither slept nor ate, walked alone, refused to bathe, and quarreled with his mother.

• The Stabbing Incident: On March 16, 2007, around 3:30 p.m., Eliseo Delmiguez, aged 50, was walking with Edgar Sapinoso along a street in Zone 3, San Miguel, Bula, Camarines Sur. Witness Rico Ballebar saw Roa seated on a sidecar of a trimobile nearby. As Delmiguez passed, Roa approached from behind and suddenly stabbed him in the left lower back with a bolo (ginunting), approximately 8 to 12 inches long. Delmiguez exclaimed “Tara man” before falling to the ground. Roa immediately fled and hid in the house of his uncle Camilo Mejaro.

• Post‑Incident Events: Barangay Captain Herminion Ballebar called for police assistance. SPO1 Hermilando Manzano and SPO1 Nelson Ballebar arrived; upon being called, Roa voluntarily surrendered and handed over the jungle knife. He was brought to the police station. Delmiguez was pronounced dead on arrival at the Bula Municipal Health Center; the necropsy report attributed death to “Hypovolemia secondary to multiple stab wounds.”

• Lower Court Findings: The trial court found that Roa failed to prove insanity by clear and convincing evidence. His past medical history, the absence of psychotic incidents between 2002 and 2007, and the circumstances of the attack—surprising the victim, fleeing, and later surrendering—did not indicate a complete deprivation of reason at the time of the offense. The Court of Appeals affirmed, noting that the defense evidence was speculative and that mere abnormality of the mind does not constitute legal insanity.

• Insanity: Whether accused‑appellant proved by clear and convincing evidence the exempting circumstance of insanity under Article 12, paragraph 1 of the Revised Penal Code such that his conviction for murder should be reversed.

• Insanity: The exempting circumstance of insanity was not established. The evidence on record—the 2001 diagnosis and confinement, the 2012 psychiatric evaluation, and the testimony of lay witnesses—did not provide clear and convincing proof that accused‑appellant was completely deprived of intelligence or freedom of will at the time immediately preceding or simultaneous with the 2007 stabbing. The 2012 diagnosis was made five years after the crime and was therefore irrelevant to the mental state in 2007; the 2001 diagnosis, while temporally closer, was still remote, and the testimony regarding it amounted to hearsay from Dr. Laguidao, who had no personal participation in that earlier assessment. Even if admissible, the 2001 diagnosis only proved Roa’s condition in 2001, not in 2007. The proper discharge from the mental hospital in 2002 signified an improvement that restored the presumption of sanity, absent contrary evidence. Moreover, the accused’s behavior surrounding the incident—approaching the victim unseen from behind, fleeing after the stabbing, and voluntarily yielding to the police—indicated that he understood the nature and wrongfulness of his act, which is incompatible with a complete absence of reason. Because the defense bore the burden of proving insanity with clear and convincing evidence and the proffered proof failed to fill the critical temporal gap, the presumption of sanity stood unrebutted. The conviction for murder, as affirmed by the Court of Appeals, was therefore upheld.

• Standard for Exempting Insanity — To exempt from criminal liability under Article 12(1) of the Revised Penal Code, insanity must involve a complete deprivation of intelligence or freedom of will at the time the offense is committed; mere abnormality of the mental faculties is not enough. The accused must prove this complete deprivation by clear and convincing evidence.

• Temporal Relevance of Insanity Evidence — The testimony or proof of an accused’s insanity must relate to the time immediately preceding or simultaneous with the commission of the offense. Evidence of insanity at another time may be given weight only if accompanied by proof of abnormal behavior immediately before or during the act.

• Presumption of Sanity and Continuity — Every person is presumed sane. While a person committed to a mental institution is presumed to continue to be insane, that presumption is displaced by a proper discharge, which indicates improvement and restores the presumption of sanity. The party pleading insanity as a defense bears the burden of establishing its existence at the crucial moment; failure to do so leaves the presumption of sanity intact.

• Effect of Post‑Offense Conduct — The conduct of the accused immediately before, during, and after the commission of the offense—such as surprising the victim, fleeing the scene, and voluntarily surrendering—may be evaluated as circumstantial evidence of consciousness of wrongdoing, negating a claim of complete mental incapacity.

• “The issue of insanity is a question of fact for insanity is a condition of the mind, not susceptible of the usual means of proof. As no man can know what is going on in the mind of another, the state or condition of a person’s mind can only be measured and judged by his behavior. Establishing the insanity of an accused requires opinion testimony which may be given by a witness who is intimately acquainted with the accused, by a witness who has rational basis to conclude that the accused was insane based on the witness’ own perception of the accused, or by a witness who is qualified as an expert, such as a psychiatrist. The testimony or proof of the accused’s insanity must relate to the time preceding or coetaneous with the commission of the offense with which he is charged.”

• “In this jurisdiction, it had been consistently and uniformly held that the plea of insanity is in the nature of confession and avoidance. Hence, 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, because the accused had already admitted committing the crime.”

• “Any one who pleads insanity as an exempting circumstance bears the burden of proving it with clear and convincing evidence. The testimony or proof of an accused’s insanity must relate to the time immediately preceding or simultaneous with the commission of the offense with which he is charged.”

• People v. Fernando Madarang, G.R. No. 132319, May 12, 2000, 332 SCRA 99 — Followed. Articulates the nature and rationale of the insanity defense and the stringent standard of complete deprivation of intelligence.

• People v. Arnold Garchitorena, G.R. No. 175605, August 28, 2009, 597 SCRA 420 — Followed. Reiterates that insanity is in the nature of confession and avoidance, so the accused is tried only on the issue of sanity.

• People v. Edwin Isla, G.R. No. 199875, November 21, 2012, 686 SCRA 267 — Followed. States that the burden of proving insanity rests on the accused and requires evidence relating to the time immediately before or during the offense.

• People v. Jugueta — Applied to modify damages; for crimes where the imposable penalty is reclusion perpetua, the proper amounts are ₱75,000 as civil indemnity, ₱75,000 as moral damages, and ₱75,000 as exemplary damages.

• Article 12, paragraph 1, Revised Penal Code — Exempts from criminal liability an imbecile or an insane person, unless the latter acted during a lucid interval. The Court applied the provision by requiring the accused to prove complete deprivation of reason; because the accused failed to do so, the exemption did not lie.

• Article 248, Revised Penal Code — Defines and penalizes murder. The conviction under this article was sustained upon proof of the elements of the killing and the qualifying circumstance of treachery.

Associate Justice Lucas P. Bersamin (Chairperson), Associate Justice Bienvenido L. Reyes, Associate Justice Marvic M.V.F. Leonen (additional member per raffle dated March 20, 2017), and Associate Justice Noel G. Tijam.