G.R. No. 227312 September 5, 2018
People of the Philippines, Plaintiff-Appellee vs. Jessie Haloc y Codon, Accused-Appellant

FACTS

Accused-appellant Jessie Haloc was charged with Murder for killing four-year-old Arnel de la Cruz and Attempted Murder for hacking nine-year-old Allan de la Cruz. The incident occurred on June 22, 2008, in Gubat, Sorsogon. Armed with a bolo, Haloc initially targeted the victims’ father, Ambrosio, who escaped. Haloc then turned his aggression on Ambrosio’s children, hacking Allan on the arm and inflicting a fatal neck wound on Arnel that nearly decapitated him. The accused pleaded not guilty, and the trial was reversed as he invoked the defense of insanity.
During trial, the defense presented testimonies from Haloc’s sister and wife, who described his history of mental disorder, including prior hospitalizations in 2003 and 2007. They testified that before the incident, he was drinking heavily, had “glazing” eyes, and acted differently. A psychiatrist confirmed his past admissions to a mental hospital but did not personally treat him. The defense argued he was in a state of insanity at the time of the crimes. The Regional Trial Court convicted Haloc, finding the defense of insanity unproven. The Court of Appeals affirmed the convictions but modified the damages awarded.

ISSUE

Whether or not the accused-appellant is exempt from criminal liability by reason of insanity.

RULING

The Supreme Court denied the appeal and affirmed the convictions. The legal logic is anchored on the principle that insanity, as an exempting circumstance under Article 12 of the Revised Penal Code, requires proof of a complete deprivation of intelligence or freedom of will at the precise moment of the crime’s commission. Mere abnormality of mental faculties, a history of mental illness, or eccentric behavior is insufficient. The burden of proof rests heavily on the defense to establish this complete deprivation by clear and convincing evidence.
The Court found the defense evidence wanting. The testimonies of relatives about past treatments and strange behavior were deemed general and inconclusive as to Haloc’s cognitive state during the criminal act. Critically, the evidence showed he could recognize his sister immediately after the hacking and voluntarily surrendered the bolo to her. His ability to identify a specific target (the father) initially, and then shift to the children, demonstrated a coherent, albeit malicious, chain of thought and purposeful action. This indicated he acted with discernment and intent, not from a complete absence of intelligence. The Court thus upheld the factual findings of the lower courts that the qualifying circumstance of treachery attended the killing of the helpless four-year-old victim. The civil indemnities were modified in line with prevailing jurisprudence.