People vs Villa Jr.

331 SCRA 142 2000 Facts: Dionito Fernandez was cutting grass when his neighbor Rodolfo Villa, Jr., a member of the CAFGU came out with his M-1 Garand rifle and shot Dionito killing him instantly (discovered later that Dionito accused him of stealing chickens). Ronald and Sheila, children of Dionito, rushed out and were also shot. Sheila was only shot in the thigh and tummy. Samuel Eclevia, attempted to wrestle the rifle but was also gunned down. Villa Jr. surrendered and was charged with multiple murder. He pleaded not guilty and invoked self defense (says that Dionito was charging at him with a bolo). His new lawyer (he changed lawyers in the middle) moved for a psychiatric examination and it was granted. He was confined in the Mental Hospital for evaluation (for insanity) for a month which resulted in the finding of Insanity or Psychosis classified as Schizophrenia. He was found to be incompetent to stand trial. After 6 months, the doctors found him fit to stand trial. After his release, he pleaded insanity as a defense, which was disregarded. Issue: The only issue to be resolved is whether accused-appellant was insane during the commission of the crimes as would exempt him from criminal liability. Held: Court was not convinced that he was insane during the commission of the crime since the evaluation did not say so in unequivocal terms. Dr. Zalsos was unsure when she testified. In order that insanity can be considered as an exempting circumstance, it must be shown to exist just before or during the commission of the offense. It must be shown beyond doubt that there was complete deprivation of reason or discernment and freedom of the will at the time of the commission of the crime, which the accused failed to prove. Insanity is evidenced by a deranged and perverted condition of the mental faculties which is manifested in language and conduct. An insane person has no full and clear understanding of the nature and consequences of his acts. We are convinced that accused-appellant was sane at the time he perpetrated the killings. The following circumstances clearly point to saneness. (a) Immediately surrendering to the Police; (b) He showed remorse during his confinement; (c) Gave a sworn statement before the Prosecutors Office after the crimes narrating the incident (admit that he was of sound mind). These are hardly the acts of a person with a sick mind. The law presumes every man to be of sound mind. Thus, a person accused of a crime who pleads the exempting circumstance of insanity has the burden of proving it.

The defense banks heavily on the findings of the psychiatrists. Doctors did not say that he was totally insane to warrant conclusion that he was insane enough to kill all those people. We agree with the trial court that the results of the examinations conducted by the psychiatrists on accused-appellant appear to be based on incomplete or insufficient facts. Records show that the psychiatrists relied mainly on the data supplied by accused-appellant and his police escort. It could be that he was insane while being evaluated and was contacted during his detention prior trial, maybe due to guilt or realizations. To be a defense it has to be there when crime was commissioned. Court affirms decision with a modification in penalties.