G.R. No. 184343 March 2, 2009
People of the Philippines, Plaintiff-Appellee, vs. Jesus Domingo, Accused-Appellant.

FACTS

Six Informations were filed against appellant Jesus Domingo for crimes committed on March 29, 2000, in San Rafael, Bulacan. The charges were: Murder for the deaths of Marvin G. Indon (Criminal Case No. 1496-M-2000) and Melissa G. Indon (Criminal Case No. 1497-M-2000); Frustrated Murder against Michelle G. Indon (Criminal Case No. 1498-M-2000), Ronaldo Galvez (Criminal Case No. 1499-M-2000), and Raquel Gatpandan Indon (Criminal Case No. 1500-M-2000); and Attempted Murder against Jeffer G. Indon (Criminal Case No. 1501-M-2000). The appellant pleaded not guilty. The prosecution evidence established that between 1:00 a.m. and 2:00 a.m., appellant forcibly entered the Indon family’s house, armed with a kitchen knife and screwdriver. He attacked Raquel Indon and her children. Marvin and Melissa Indon died from their wounds. Michelle, Jeffer, and Raquel survived with injuries. Neighbor Ronaldo Galvez intervened and was also wounded. Raquel positively identified the appellant, whom she knew as “Doser,” as the assailant, recognizing him under the kitchen light. The defense presented appellant’s mother and sister, who testified he had a history of mental illness and was acting strangely before the incident. A psychiatrist diagnosed him with Paranoid Schizophrenia but found him mentally fit to stand trial. The Regional Trial Court convicted appellant but appreciated the mitigating circumstance of voluntary surrender. The Court of Appeals affirmed the convictions but deleted the appreciation of voluntary surrender.

ISSUE

The core issue is whether the Court of Appeals erred in finding appellant guilty beyond reasonable doubt of the crimes charged and in not appreciating his defense of insanity.

RULING

The Supreme Court denied the appeal and affirmed the Court of Appeals’ Decision with modifications. The Court held that the prosecution proved appellant’s guilt beyond reasonable doubt. Raquel Indon’s positive identification of appellant as the assailant was credible and reliable, as she knew him and recognized him under sufficient illumination. The defense of insanity was rejected. The Court reiterated that the presumption of sanity prevails, and the burden of proof rests on the defense to prove the accused’s complete deprivation of intelligence or freedom of will at the time of the crime. The defense evidence, including the psychiatric testimony, failed to conclusively establish that appellant was insane during the commission of the offenses. The psychiatrist’s finding of fitness to stand trial did not equate to sanity at the time of the crime, and the testimony of family members was insufficient to overturn the presumption of sanity. The qualifying circumstances of treachery and abuse of superior strength were properly appreciated for the murder charges. The Court modified the penalties and awarded civil indemnities, moral damages, and exemplary damages to the victims and their heirs, with specified amounts for each crime.