G.R. No. 224886 September 4, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ROGER RACAL @ RAMBO, Accused-Appellant

FACTS

Accused-appellant Roger Racal was charged with Murder for stabbing Jose Francisco to death on April 19, 2006, in Cebu City. Prosecution evidence established that around 4:00 a.m., while Francisco and other tricycle drivers were waiting for passengers, Racal, standing nearby, suddenly shouted that Francisco was a traitor. When Francisco asked why he was being called such, Racal, without warning, approached and stabbed him multiple times with a knife. Racal then fled the scene. The prosecution presented eyewitnesses to the sudden and unprovoked attack.
Racal admitted to the stabbing but interposed the defense of insanity. He presented expert witnesses who testified that he had a predisposition to “snap” into episodes where he would lose rational judgment and act involuntarily, allegedly rendering him incapable of distinguishing right from wrong at the time of the incident. The Regional Trial Court convicted him of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the damages awarded. Racal appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming Racal’s conviction for Murder, specifically in rejecting his defense of insanity and in appreciating the qualifying circumstance of treachery.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modifications to the damages. The Court upheld the finding that the prosecution proved all elements of Murder beyond reasonable doubt. On the defense of insanity, the Court reiterated the legal presumption of sanity. The burden of proof to rebut this presumption lies with the accused, and it must be shown by clear and convincing evidence that the accused was completely deprived of intelligence or reason at the very moment of the crime’s commission. The Court found Racal’s evidence insufficient. The testimonies of his expert witnesses, while indicating a history of depression and psychotic features, failed to conclusively establish that he was in a state of complete insanity during the stabbing. His actions before, during, and after the incident—such as making a provocative statement, executing a sudden attack, and immediately fleeing—demonstrated a coherent sequence of acts inconsistent with a total loss of cognitive faculties.
Regarding the qualifying circumstance, the Court affirmed the presence of treachery (alevosia). The attack was sudden and unexpected, executed in a manner that deprived the unarmed victim, who was merely eating, of any opportunity to defend himself or retaliate. This method ensured the execution of the crime without risk to the assailant. The Court modified the awarded damages in line with prevailing jurisprudence, increasing civil indemnity and moral damages to ₱75,000.00 each, awarding ₱75,000.00 as exemplary damages, and replacing the actual damages with ₱50,000.00 as temperate damages, all with legal interest.