GR 172697; (September 2007) (Digest)
G.R. No. 172697; September 25, 2007
PEOPLE OF THE PHILIPPINES, Appellee, vs. REYNALDO VILLANUEVA y MARQUEZ, Appellant.
FACTS
On January 21, 2000, appellant Reynaldo Villanueva killed his eight-year-old niece, Angelica, by boxing and kicking her, and also mauled his two young nephews, Rexie and Enrique, Jr. Angelica died from her injuries, Rexie sustained serious injuries that could have been fatal without medical intervention, and Enrique, Jr. suffered a broken mouth. Appellant was charged with murder, frustrated murder, and attempted murder. At trial, he pleaded insanity, claiming he had no knowledge of committing the acts. He presented evidence of a psychiatric history, including testimony from Dr. Clarette Dy, who diagnosed him with paranoid schizophrenia, episodic with interepisode residual symptoms. Appellant also detailed his activities on the day of the crime, including a medical check-up, drinking alcohol at various establishments, and a confrontation with his mother before the attacks.
ISSUE
Whether the appellant’s plea of insanity exempts him from criminal liability for the crimes of murder, frustrated murder, and attempted murder.
RULING
The Supreme Court affirmed the appellant’s conviction but modified the penalty for frustrated murder. The Court rejected the defense of insanity. While medical evidence established appellant suffered from a mental disorder, it did not prove he was completely deprived of intelligence or freedom of will at the precise moment of the crimes. The legal presumption of sanity prevails unless conclusively overturned. The Court found appellant’s detailed recollection of events leading up to the crimes demonstrated consciousness and discernment. His ability to engage in coherent, sequential activities—consulting a doctor, drinking, singing at a bar, purchasing food, and cooking—negated a total absence of reason. The illness was deemed to have only diminished, not obliterated, his willpower, constituting a mitigating circumstance under Article 13(9) of the Revised Penal Code, but not an exempting one. Consequently, he was correctly held liable. The penalty for frustrated murder was modified to an indeterminate sentence of six years and one day of prision mayor as minimum to twelve years and one day of reclusion temporal as maximum.