G.R. No. 223566. June 27, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. JUNIE (OR DIONEY) SALVADOR, SR. Y MASAYANG, ACCUSED-APPELLANT.

FACTS

Accused-appellant Junie Salvador, Sr. was charged with five counts of murder for hacking to death his two-year-old son, his live-in partner Miraflor Realo, her 12-year-old daughter Rossana, and his two nieces, aged three and one. The prosecution established that on February 11, 2011, after appearing normal earlier in the day, Salvador was seen chasing and hacking Miraflor. When a barangay official responded, Salvador voluntarily surrendered, stating, “If I want to kill a lot of people, I could but I only killed my family.” The bodies of the five victims were subsequently discovered inside his house.
The defense interposed the claim of insanity. A psychiatrist testified that based on a review of records from an examination conducted 16 months after the incident, accused-appellant was later treated for psychosis and could have been experiencing a psychotic episode at the time of the crimes. He claimed he could not remember the events.

ISSUE

Whether the Court of Appeals correctly affirmed accused-appellant’s conviction for five counts of murder, rejecting his defense of insanity.

RULING

Yes, the Supreme Court affirmed the conviction. The defense of insanity failed to meet the requisite legal standard. Jurisprudence consistently holds that the insanity defense requires a complete deprivation of intelligence or freedom of the will at the very moment of the crime’s commission. The evidence presented, primarily a psychiatrist’s opinion based on a post-facto review of records from an examination long after the incident, was insufficient to prove this complete deprivation. The Court found the opinion conjectural, noting the doctor never personally examined accused-appellant near the time of the incident.
In contrast, the prosecution evidence was overwhelming. Eyewitness testimony detailed the attack on Miraflor. Accused-appellant’s own spontaneous declaration upon surrender—“I only killed my family”—constituted a clear admission of guilt and demonstrated a conscious awareness of his acts. His responsive behavior during police booking further negated a claim of complete insanity. The qualifying circumstance of treachery was correctly appreciated for the murders of the four victims killed inside the home, as the attacks were sudden and employed means that ensured the defenseless victims, particularly the young children, could not resist. The Court modified the awarded damages in accordance with prevailing jurisprudence.