GR 130210; (December, 1999) (Digest)
G.R. No. 130210, December 8, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RALPH VELEZ DIAZ alias “JIMBOY,” accused-appellant.
FACTS
On December 3, 1996, eleven-year-old Francis Bart Fulache went with his brother Felbart and accused-appellant Ralph Velez Diaz to Pier 3 in Cebu City. Francis Bart and Diaz proceeded to Pier 4, after which the victim never returned home. The following day, his nude and physically abused body was found under Bulacao Bridge. An autopsy revealed the cause of death as traumatic intracranial hemorrhage with skull fracture and noted multiple lacerations in the rectum, which the medico-legal officer opined could have been caused by a male organ. During the wake, Diaz acted suspiciously and was invited for questioning. He executed an extra-judicial confession and later reenacted the crime, but the trial court declared these inadmissible due to constitutional infirmities. The defense presented Dr. Wilson Tibayan, who diagnosed Diaz with pedophilia but clarified this disorder did not constitute legal insanity, as the accused could still distinguish right from wrong.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of murder qualified by treachery.
RULING
Yes. The Supreme Court affirmed the conviction for murder but modified the penalty to reclusion perpetua. The Court found that the totality of circumstantial evidence sufficiently established guilt. The evidence showed that Diaz was the last person seen with the victim, his bizarre behavior at the wake indicated consciousness of guilt, and the nature of the fatal injuries was consistent with a violent assault. The Court ruled that treachery was present because the attack on the young, vulnerable victim was sudden and deliberate, ensuring the execution of the crime without risk to the assailant. The defense of insanity failed, as the defense expert witness himself testified that pedophilia, while a mental disorder, does not deprive a person of the capacity to understand the wrongfulness of his acts. The burden of proof for insanity rests on the defense, and this burden was not discharged. The civil indemnity was set at P50,000.00, with modified awards for moral and exemplary damages.