G.R. No. 129291 ; July 3, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ENRICO A. VALLEDOR, accused-appellant.

FACTS

On March 6, 1991, accused-appellant Enrico Valledor, a provincial jail guard, entered a house in Puerto Princesa City and, without provocation, stabbed Roger Cabiguen on the forearm. He then stabbed Elsa Rodriguez in the chest, declaring, “I had my revenge, Elsa,” before fleeing. Rodriguez died, and Cabiguen survived. A neighbor, Ricardo Maglalang, was also stabbed by Valledor during the incident. Valledor was charged with murder for Rodriguez’s death, frustrated murder for Cabiguen, and attempted murder for Maglalang. At trial, the prosecution established a motive: Valledor had long suspected Cabiguen of killing his pet dog and had been jilted and humiliated by Rodriguez.
The defense centered on the exempting circumstance of insanity. Evidence showed that in January 1990, Valledor was diagnosed with “psychosis with schizophrenia” and prescribed medication. His mother testified that he had stopped taking his medicine days before the stabbing. On the morning of the crime, a barangay official found Valledor acting erratically, crying about his family being killed, and had to escort him. Valledor escaped custody just hours before the attacks.

ISSUE

Whether or not accused-appellant Enrico Valledor is exempt from criminal liability by reason of insanity.

RULING

The Supreme Court affirmed the conviction but modified the penalties. The Court rejected the defense of insanity. The legal logic requires that for insanity to be an exempting circumstance, the accused must prove that at the very moment of committing the act, he was deprived of complete intelligence or lacked freedom of will. Insanity must exist at the time of the crime’s commission. The Court found Valledor’s actions demonstrated a clear, rational design. He specifically sought out his victims in a confined room, uttered words indicating a pre-existing grudge (“I had my revenge”), and fled immediately after. This sequence of events—targeted attack, declaration of motive, and flight—shows consciousness and intelligent direction of his acts, negating a complete deprivation of intelligence. While his medical history and strange behavior prior to the crime were noted, these alone do not establish that he was insane at the precise moment he carried out the stabbings. The evidence failed to meet the high standard of proof required for the exempting circumstance of insanity. Consequently, the trial court’s finding of guilt was upheld. However, for the wounding of Roger Cabiguen, the Court modified the crime from frustrated murder to attempted murder, as the prosecution did not sufficiently prove that the injury inflicted was inherently fatal, a necessary element for frustrated murder.