G.R. No. 207397 . September 24, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. CARPIO MARZAN Y LUTAN, ACCUSED-APPELLANT.

FACTS

Accused-appellant Carpio Marzan was charged with Murder for the killing of his brother Apolonio and Frustrated Murder for the stabbing of another brother, Bernardo, on May 22, 2003, in Camiling, Tarlac. The prosecution established that Marzan entered Apolonio’s house, was heard uttering hostile words, and subsequently emerged with a bloodied bolo. Apolonio was found dead from multiple stab wounds. Bernardo testified that when he tried to intervene, Marzan declared, “you are also one of them,” and stabbed him. The defense did not contest the stabbings but interposed the defense of insanity. Marzan’s wife, Isabel, testified that he had a history of behavioral issues, appeared nervous and tulala (stunned), and on the day of the incident was mumbling and made a statement suggesting a preemptive attack before running to Apolonio’s house. After the attacks, he reportedly sat down in a daze until arrested.

ISSUE

The core issue is whether the accused-appellant successfully proved the exempting circumstance of insanity at the time of the commission of the crimes.

RULING

The Supreme Court affirmed the conviction for Murder and Frustrated Homicide, rejecting the defense of insanity. The legal logic is anchored on the principle that insanity is an affirmative defense, and the burden of proof rests heavily upon the accused to prove with clear and convincing evidence that he was completely deprived of intelligence or reason at the exact moment of the criminal act. The Court emphasized that the defense must establish a complete deprivation of freedom of will, not merely a diminished capacity. The testimony of the accused’s wife regarding his general behavior and being tulala before and after the incident was deemed insufficient. Crucially, the prosecution evidence demonstrated purposeful and coordinated actions: Marzan sought out the victims, made declaratory statements indicating a motive (“I have an enemy,” “you are also one of them”), and employed a lethal weapon effectively. These acts showed a conscious effort to achieve a specific criminal objective, which is utterly incompatible with a complete absence of rational faculty. The Court modified the penalties and damages awarded. For Murder, exemplary damages were increased to P75,000. For the crime against Bernardo, properly classified as Frustrated Homicide (as the attack was not deliberate), the indeterminate penalty was adjusted, and civil indemnity and moral damages of P30,000 each were awarded, with all damages subject to 6% annual interest from finality until paid.