G.R. No. 113691 February 6, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO MEDINA y CATUD, accused-appellant.

FACTS

Accused-appellant Alberto Medina y Catud was charged with murder for stabbing Andres M. Dalisay with a balisong knife on the night of May 20, 1992, in Barangay Kaingin, San Pascual, Batangas. The prosecution’s evidence, primarily from eyewitness Larry Andal, established that after a party, as Dalisay was walking home, appellant, who was waiting along the way, stabbed him. A struggle ensued, Dalisay broke free and ran, but appellant chased and stabbed him multiple more times, resulting in Dalisay’s death from eight stab wounds. The defense interposed the exempting circumstance of insanity. Appellant testified that after dancing with the victim at the party, the victim, appearing drunk, confronted and hit him, and threatened to kill him while reaching for something. Appellant claimed he then saw the victim as a devil with horns, prompting him to stab him. To support the insanity defense, the defense presented the testimony of appellant’s sister, Lorna Medina, who recounted his unusual behavior and prior confinement at the National Mental Hospital in 1982 for “schizophreniform disorder,” and Dr. Teresita Adigue, a psychologist, who testified that based on a January 1992 evaluation, appellant was suffering from depression, exhibited homicidal tendencies, and did not know right from wrong. The trial court convicted appellant of murder, sentenced him to reclusion perpetua, and ordered him to pay indemnity, rejecting the insanity defense.

ISSUE

Whether or not the accused-appellant is entitled to the exempting circumstance of insanity under Article 12, paragraph 1 of the Revised Penal Code.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the trial court’s decision with MODIFICATION regarding the penalty. The Court held that the defense of insanity was not sufficiently proven. The law presumes every offender to be of sound mind, and the exempting circumstance of insanity must be established by clear and competent evidence showing the accused completely lost his reason or was demented immediately prior to or at the very moment of the crime. The testimony of Dr. Adigue was found insufficient as she was not a psychiatrist, her evaluation was brief and based on incomplete behavioral history, and her methods and conclusions were deemed inconclusive by the trial court. The prior 1982 confinement was too remote and did not prove insanity at the time of the crime in 1992. Appellant’s own actions—surrendering after the stabbing, fleeing the scene, and the manner of the attack—indicated consciousness of his acts. The Court found the qualifying circumstance of treachery present, as the attack was sudden and unexpected, denying the victim any chance to defend himself. However, the Court ruled that the trial court erred in appreciating the generic aggravating circumstance of evident premeditation due to lack of conclusive proof of the requisite elements. With no mitigating or aggravating circumstances, the penalty for murder, reclusion perpetua to death, was imposed in its medium period, which is reclusion perpetua. The civil indemnity was increased to P50,000.00.