G.R. No. 219113 , APRIL 25, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ROLAND MIRAÑA Y ALCARAZ, Accused-Appellant

FACTS

Accused-appellant Roland Miraña was charged with Murder for hacking to death the 73-year-old victim, Dominga Agnas, with a bolo. The prosecution established that the victim had previously reprimanded the accused for stealing fruits and had been harassed by him. On the morning of the incident, a neighbor heard cries and found the victim dead. Accused-appellant immediately admitted the killing to responding police officers and surrendered the weapon. The victim’s son also testified that the accused confessed to the killing during a visit to the mental hospital where he was later confined.
The defense, during a reverse trial, interposed the justifying circumstance of insanity. The accused’s mother and sister testified that he exhibited odd behavior prior to the incident, such as talking to himself and claiming the victim was a witch. They attributed this to a prior incident where his nose was bitten. The accused himself claimed no recollection of the events. The Regional Trial Court convicted him of Murder, appreciating the qualifying circumstance of abuse of superior strength, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for Murder, specifically in rejecting his defense of insanity and in appreciating the qualifying circumstance of abuse of superior strength.

RULING

The Supreme Court modified the conviction from Murder to Homicide. On the defense of insanity, the Court held that the accused failed to prove he was completely deprived of intelligence or freedom of will at the time of the act. The evidence of odd behavior—smiling alone, calling a chicken, or labeling the victim a witch—merely indicates mental abnormality, not the total deprivation of discernment required by law to exempt one from criminal liability. His coherent admission of guilt to the police and his son immediately after the act demonstrated consciousness of his actions.
Regarding the qualifying circumstance, the Court ruled that abuse of superior strength was not proven. While the accused was a young male with a bolo and the victim was an elderly, unarmed woman, the prosecution did not present evidence showing that the accused deliberately used his superior strength to facilitate the crime. The circumstance was not alleged with particularity in the Information, and its appreciation was not justified by the evidence on record. Absent any qualifying circumstance, the killing constitutes Homicide, not Murder. The Court sentenced him to an indeterminate penalty and awarded damages accordingly.