G.R. No. 223114 . November 29, 2017.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JONAS PANTOJA Y ASTORGA, Accused-Appellant.

FACTS

Accused-appellant Jonas Pantoja was charged with the murder of a six-year-old child, AAA. The prosecution established that on July 22, 2010, Pantoja, who had a history of mental illness and was a recent escapee from the National Center for Mental Health, entered the victim’s house and repeatedly stabbed him with a kitchen knife, causing fatal injuries. The victim’s mother discovered the crime scene, finding Pantoja holding the knife and the child bloodied on the floor. Pantoja appeared dazed and unresponsive. The defense did not contest the commission of the act but asserted that Pantoja was insane at the time of the offense. Both his mother and his own testimony detailed his long history of schizophrenia, hospital confinements, and erratic behavior, including a period of escape prior to the incident.

ISSUE

The core issue is whether accused-appellant Jonas Pantoja was insane at the time of the crime’s commission, thereby exempting him from criminal liability under Article 12 of the Revised Penal Code.

RULING

The Supreme Court affirmed the conviction for murder but modified the damages. The Court rejected the defense of insanity. The legal logic is anchored on the principle that the defense of insanity requires a complete deprivation of intelligence, reason, or discernment at the very moment the crime was committed. It is not enough to have a history of mental illness. The accused must prove that he had no conscious control over his actions and could not distinguish right from wrong during the criminal act. Here, the evidence showed Pantoja had the presence of mind to locate and enter the victim’s house, select a weapon, and inflict multiple, directed stab wounds. His subsequent dazed state does not equate to legal insanity at the precise time of the stabbing. Furthermore, his mother’s testimony indicated he had been taking his medication, and his own admission that he would sometimes stop taking it when he “felt well” undermined the claim of complete deprivation of reason. The Court found the qualifying circumstance of treachery present due to the victim’s extreme youth and helplessness, and the cruelty against a minor as an aggravating circumstance. The penalty of reclusion perpetua was upheld, with civil indemnity, moral damages, and exemplary damages each set at Seventy-Five Thousand Pesos (₱75,000.00).