G.R. No. 110855 June 28, 1999
People of the Philippines, plaintiff-appellee, vs. Edwin Cañeta y Villapando and Antonio Abes y Gallego, accused-appellants.

FACTS

Accused-appellants Edwin Cañeta and Antonio Abes were charged with the special complex crime of robbery with homicide. The prosecution established that on October 12, 1988, Teodorico Muñoz, a cash delivery man, was accosted in Manila while carrying P50,000.00. Cañeta stabbed Muñoz with a balisong, while Abes grabbed the bag containing the money. The victim was pronounced dead on arrival at the hospital. Witness Maria Manalac heard the victim’s cries and saw two individuals fleeing. Cañeta was apprehended by a mob near the scene with a fan knife, and Abes was later positively identified by another eyewitness, Evangeline Mico.
During trial, the defense for Cañeta moved for a mental examination, resulting in a suspension of proceedings. The National Center for Mental Health reported that Cañeta was suffering from “Schizophrenia, Chronic Undifferentiated Type” but was found to be mentally fit to stand trial. Both accused were convicted by the Regional Trial Court and sentenced to reclusion perpetua. They appealed, with Cañeta arguing insanity as an exempting circumstance and Abes contesting his identification.

ISSUE

The primary issues were: (1) Whether accused-appellant Edwin Cañeta can be exempted from criminal liability on the ground of insanity; and (2) Whether accused-appellant Antonio Abes was properly identified as a participant in the crime.

RULING

The Supreme Court affirmed the conviction with modification. On the first issue, the Court ruled that Cañeta failed to prove the exempting circumstance of insanity. The legal presumption is that every person is sane. To successfully invoke insanity, the accused must prove a complete deprivation of intelligence, meaning there was no consciousness of the act or a complete absence of the power to discern. Mere abnormality of mental faculties or a diagnosis of a mental disorder is insufficient; it must be shown that the insanity existed at the very moment the crime was committed. The medical finding of fitness to stand trial negated the claim of complete deprivation of reason during the criminal act.
On the second issue, the Court upheld the positive identification of Antonio Abes by eyewitness Evangeline Mico. The defense’s argument that Mico did not know Abes’s name prior to the incident was irrelevant. Credible identification is based on the witness having seen the accused commit the crime, not on prior acquaintance. The trial court’s assessment of the witness’s credibility is accorded great respect. The crime was duly proven as robbery with homicide, where the killing occurred by reason or on the occasion of the robbery. The Court modified the civil indemnity to P50,000.00 in accordance with prevailing jurisprudence.