G.R. No. 130487 ; June 19, 2000
The People of the Philippines, plaintiff-appellee, vs. Roberto Estrada, accused-appellant.

FACTS

Accused-appellant Roberto Estrada was charged with murder for stabbing a security guard inside a cathedral during a confirmation rite. Before his arraignment, the Public Attorney’s Office filed an urgent motion to suspend the proceedings and commit Estrada to a psychiatric ward, alleging he suffered from a mental defect and had a prior confinement history. The trial court, after propounding questions to Estrada and finding his answers intelligible, denied the motion on the same day. The arraignment proceeded, and a plea of not guilty was entered.
During trial, the prosecution established that Estrada, in a crowded cathedral, refused to vacate the Bishop’s chair. When the security guard intervened, Estrada stabbed him, resulting in the victim’s death. Estrada later filed a demurrer to evidence, which was denied. The defense then presented evidence, including medical certificates from Baguio General Hospital diagnosing Estrada with “Schizophrenia, Paranoid Type” both before and after the incident. The trial court convicted Estrada of murder, imposing the death penalty, citing the aggravating circumstance of committing the crime in a place of worship.

ISSUE

Whether the trial court gravely erred in denying the motion to suspend the arraignment and in failing to order a mental examination of the accused, thereby violating his right to due process.

RULING

Yes. The Supreme Court nullified the proceedings and remanded the case. The trial court committed a grave error by denying the motion for a mental examination based solely on its brief colloquy with the accused. The right to be presumed innocent includes the right to be mentally competent to stand trial. A defendant must have sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding and a rational as well as factual understanding of the proceedings against him.
The defense presented substantial evidence raising a bona fide doubt regarding Estrada’s competence, including medical certificates diagnosing him with paranoid schizophrenia. The trial court’s superficial inquiry was insufficient to assess his true mental state for the purpose of standing trial. The failure to order a psychiatric examination, despite this evidence, deprived Estrada of a fundamental right and rendered the trial void. Consequently, the judgment was set aside, and the case was remanded for a proper determination of the accused’s mental capacity and for further proceedings in accordance with law.