GR 216453; (March, 2022) (Digest)
G.R. No. 216453. March 16, 2022.
OLIGARIO TURALBA Y VILLEGAS, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Oligario Turalba y Villegas was charged with Carnapping under Republic Act No. 6539, as amended. The Information alleged that on November 20, 2007, in Olongapo City, he took, without consent and with intent to gain, a 1996 Honda CRV belonging to Gregorio Calimag. The prosecution established that Calimag parked his car, left the key inside, and shortly after saw it being driven away. He gave chase, eventually cornering the vehicle in traffic, where he apprehended Oligario and called the police. Officers recovered a butterfly knife from Oligario. In his defense, Oligario presented Dr. Ma. Lourdes Labarcon Evangelista, who testified that she evaluated him on October 24, 2007, and assessed him with psychosis due to alcohol and methamphetamine use, which could lead to irrational and impulsive acts. The Regional Trial Court convicted Oligario, and the Court of Appeals affirmed the conviction, rejecting his insanity defense.
ISSUE
Whether or not the Court of Appeals erred in affirming Oligario Turalba’s conviction for Carnapping and in not appreciating the exempting circumstance of insanity or, alternatively, a mitigating circumstance.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court held that Oligario failed to prove the exempting circumstance of insanity. Insanity, as a complete deprivation of intelligence, reason, or discernment at the time of the crime, must be established with clear and convincing evidence. The testimony of Dr. Evangelista was insufficient as it was based on a single evaluation prior to the incident and did not conclusively prove Oligario’s mental state at the precise time of the carnapping. The manner of committing the crime—taking a car, driving it, and attempting to flee—demonstrated consciousness of his actions. Furthermore, the Court ruled that the mitigating circumstance of an illness diminishing the exercise of will-power under Article 13(9) of the Revised Penal Code cannot be applied to crimes under special laws, such as Carnapping under R.A. No. 6539, in the absence of an express provision. The penalty imposed by the RTC, an indeterminate sentence of 14 years and 8 months as minimum to 17 years and 4 months as maximum, was affirmed as being in accordance with the Indeterminate Sentence Law.