G.R. No. 105641 March 10, 1994
MIGUEL R. ZOSA, petitioner, vs. THE HONORABLE COURT OF APPEALS, THE PEOPLE OF THE PHILIPPINES and ANDRESA Y. RAFFINAN, respondents.

FACTS

In 1981, a complaint for libel was filed against petitioner Miguel R. Zosa, a lawyer, by his aunt, private respondent Andresa Y. Raffinan, in the Regional Trial Court of Cebu (Criminal Case No. CU-9278). The petitioner represented himself during the trial. On February 1, 1982, the trial court rendered a decision finding him guilty of libel, sentencing him to pay a fine and moral damages. This judgment became final and executory, and a writ of execution was issued, leading to the levy and sale of the petitioner’s property rights. Nine years later, on February 6, 1991, the petitioner filed a petition with the Court of Appeals (CA-G.R. SP No. 24203) for the Declaration of Nullity of Proceedings in the libel case. He alleged that he became insane during the trial and subsequent proceedings, specifically suffering from a schizophrenic disorder, paranoid type, starting sometime in 1981, which rendered him unaware of the proceedings and unable to intelligently defend himself. He supported this claim with a certification dated December 18, 1990, from Dr. Pureza T. Onate, stating he had been under professional care in November 1989 and had started having psychiatric problems in 1981. The Court of Appeals dismissed the petition on August 30, 1991, and denied his motion for reconsideration on April 23, 1992. The appellate court held that the petition lacked merit as it did not allege extrinsic or collateral fraud, the sole ground for annulment of judgment, and that the evidence of insanity was insufficient and pertained to a period long after the trial.

ISSUE

Whether the Court of Appeals erred in not holding that the petitioner’s alleged insanity during the trial of the libel case, where he acted as his own counsel, constitutes a ground for annulment of judgment, and in not receiving evidence on the competency of Dr. Onate and the correctness of her finding regarding his insanity.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the petitioner’s contention was devoid of merit. First, the petitioner’s claim of insanity during the trial assumes an established fact, but the burden of proving insanity rests upon the one alleging it, as the law presumes every person to be sane. The Court agreed with the Court of Appeals that the petitioner’s evidence, particularly Dr. Onate’s certification issued nine years after the trial, was insufficient to prove his claim of insanity at the time of trial. The certification failed to specify the exact nature, duration, and debilitating effect of the alleged psychiatric problem in 1981, and Dr. Onate’s competence to testify on his mental state nine years prior was doubtful. Second, regarding the petitioner’s plea for the Court of Appeals to receive evidence on Dr. Onate’s findings, the Supreme Court stated it would be next to impossible to determine his mental condition in 1981 based on an examination in 1989, citing a prior case (People vs. Balondo) where it was held that ascertaining mental condition years after the fact is not feasible. The Court emphasized that the sole ground for annulment of judgment is extrinsic or collateral fraud, which was not present, and the petitioner’s alleged insanity, even if proven, did not constitute such fraud as it was not attributable to the adverse party.