GR 216021; (March, 2016) (Digest)
G.R. No. 216021. March 02, 2016.
SOLOMON VERDADERO Y GALERA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Solomon Verdadero y Galera was charged with Murder for stabbing Romeo B. Plata to death on March 12, 2009, in Baggao, Cagayan. During trial, he invoked the defense of insanity. The prosecution evidence established that after a confrontation at the police station regarding a stolen fan belt, Verdadero stabbed the victim multiple times with a Rambo knife near a drugstore. The victim died from his wounds. The defense presented evidence that Verdadero had been an outpatient at the Cagayan Valley Medical Center (CVMC) Psychiatric Department since 1999, was diagnosed with schizophrenia in 2003, had a history of violent behavior and confinement, and suffered a relapse around the time of the incident. A court-appointed psychiatrist, Dr. Ethel Maureen Pagaddu, confirmed his diagnosis and agreed he had a relapse on the day of the stabbing. The Regional Trial Court (RTC) convicted Verdadero of the lesser crime of Homicide, ruling the prosecution failed to prove qualifying circumstances but that the defense failed to prove insanity at the time of the crime. The Court of Appeals (CA) affirmed the conviction. Verdadero filed this petition, arguing his insanity was established by clear and convincing evidence.
ISSUE
Whether the Court of Appeals gravely erred in affirming the petitioner’s conviction despite the fact that his insanity at the time of the incident was established by clear and convincing evidence.
RULING
The Supreme Court GRANTED the petition. It held that the defense of insanity was sufficiently proven. The Court ruled that the standard for insanity as an exempting circumstance is that the accused must be shown to have been completely deprived of intelligence or reason at the time of the commission of the crime. The evidence, including the long history of schizophrenia, prior violent incidents, medical diagnoses, and the expert opinion of Dr. Pagaddu that Verdadero had a relapse on the very day of the stabbing, constituted clear and convincing proof that he was in a state of insanity. The Court found that the prosecution failed to rebut this evidence or prove he was in a lucid interval. Consequently, Verdadero was exempt from criminal liability under Article 12 of the Revised Penal Code. The Court set aside the CA decision and the RTC judgment. Verdadero was ordered confined at the National Center for Mental Health or a similar institution until he is certified fit to be released. He was also ordered to pay civil indemnity, moral damages, and actual damages to the victim’s heirs.