GR 225599; (March, 2017) (Digest)
G.R. No. 225599 March 22, 2017
People of the Philippines, Plaintiff-Appellee vs. Christopher Mejaro Roa, Accused-Appellant
FACTS
Accused-appellant Christopher Mejaro Roa was charged with the murder of Eliseo Delmiguez. The prosecution established that on March 16, 2007, Roa, without any provocation, suddenly stabbed Delmiguez from behind with a ginunting (bolo) while the victim was walking on a street in Barangay San Miguel, Bula, Camarines Sur. The attack resulted in Delmiguez’s death from hypovolemia secondary to multiple stab wounds. Roa fled but later voluntarily surrendered to police officers.
At trial, Roa interposed the defense of insanity, claiming he suffered from schizophrenia. Evidence showed he had a history of mental disorder, with episodes dating back to 2001, consultations at a mental hospital, and prescriptions for antipsychotic medication which he could not sustain due to financial constraints. Relatives testified to his unusual behavior, including talking to himself and refusing to bathe, around the time of the incident.
ISSUE
Whether the Court of Appeals correctly affirmed the trial court’s finding that accused-appellant is guilty of murder, rejecting his defense of insanity.
RULING
The Supreme Court affirmed the conviction. The defense of insanity, as an exempting circumstance, was not proven with clear and convincing evidence. The legal logic requires that the accused must be completely deprived of reason or discernment and freedom of will at the exact time of the crime’s commission. While Roa presented a history of mental illness, this alone is insufficient. The evidence failed to establish that he was in a state of complete deprivation of intelligence during the stabbing itself. His actions before, during, and after the incident—sitting calmly before the attack, suddenly and directly assaulting the victim, immediately fleeing, and then voluntarily surrendering and handing over the weapon—demonstrated a consciousness of his acts and a desire to evade capture. These coordinated actions indicate a degree of discernment and control inconsistent with total insanity. The Court modified the awarded damages in accordance with prevailing jurisprudence, imposing civil indemnity, moral damages, and exemplary damages of ₱75,000 each, all with legal interest. The penalty of reclusion perpetua was sustained.