GR 218425; (September, 2017) (Digest)
G.R. No. 218425. September 27, 2017.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. WILSON CACHO Y SONGCO, ACCUSED-APPELLANT.
FACTS
On January 2, 2004, police and fire personnel responded to a fire report in Rodriguez, Rizal. They discovered the burned house of Mario Balbao and, underneath debris, his headless, charred body. The brother and wife of accused-appellant Wilson Cacho informed the authorities that Cacho was the perpetrator and that he was a former patient of the National Center for Mental Health (NCMH). At Cacho’s residence, police found a shallow pit with ash and a human skull, believed used to burn the victim’s head. Upon arrest, Cacho allegedly admitted to the killing and arson but acted strangely. He was confined at the NCMH after inquest. The Regional Trial Court convicted Cacho of Murder and Destructive Arson, sentencing him to reclusion perpetua for each crime. The Court of Appeals affirmed the conviction. Cacho appealed, arguing insanity and insufficient proof of the crimes’ elements.
ISSUE
The core issues were: (1) whether the defense of insanity was sufficiently proven to exempt Cacho from criminal liability; and (2) whether the crimes of Murder and Destructive Arson were proven beyond reasonable doubt.
RULING
The Supreme Court modified the lower courts’ decisions. On the first issue, the defense of insanity failed. The Court reiterated that insanity must be proven to exist at the very moment of the crime’s commission. While evidence showed Cacho had a history of mental illness and was confined post-arrest, this did not conclusively establish his state of mind on January 1, 2004. His actions—beheading the victim, burning the head and the house to conceal the crime—demonstrated a conscious effort to evade detection, indicative of an awareness of wrongdoing. Thus, he was not exempt from liability.
On the second issue, the Court held the qualifying circumstances for Murder were not proven. Treachery requires proof of the specific manner of attack, which was absent here as no eyewitness testified. Evident premeditation and nighttime were not sufficiently established. Consequently, the crime was properly Homicide, not Murder. For Destructive Arson under Article 320(5) of the Revised Penal Code, the prosecution proved the house was burned to conceal the homicide, a qualifying purpose under the law. The penalty was correctly reclusion perpetua. The Court ultimately convicted Cacho of Homicide and Destructive Arson, imposing an indeterminate penalty for Homicide and affirming reclusion perpetua for Arson, with corresponding damages.