G.R. No. 248202 . October 13, 2021.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. LEONARDO MACALINDONG Y ANDALLON, ACCUSED-APPELLANT.

FACTS

Accused-appellant Leonardo Macalindong was charged with the murder of his live-in partner, Jovelia Malinao y Panot, on February 10, 2007, in Oriental Mindoro. The Information alleged the killing was attended by treachery, evident premeditation, and abuse of superior strength. During trial, the prosecution presented the testimony of the couple’s seven-year-old daughter, Lyn Joy Macalindong, who witnessed appellant stab Jovelia multiple times during a quarrel inside their home. The defense and prosecution stipulated on the testimonies of police officers regarding the arrest and investigation, and on the medical findings from the victim’s death certificate. Appellant testified that he could not remember the incident due to blacking out and claimed insanity, submitting medical certificates indicating he was suffering from schizophrenia. The Regional Trial Court convicted appellant of murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction with modifications, also appreciating the qualifying circumstance of abuse of superior strength and increasing the damages awarded.

ISSUE

1. Whether the exempting circumstance of insanity should be credited to appellant.
2. Whether appellant was properly convicted of murder.

RULING

1. On the defense of insanity: The Supreme Court ruled that appellant’s defense of insanity must fail. The Court held that insanity, as an exempting circumstance under Article 12 of the Revised Penal Code, requires a complete deprivation of intelligence or discernment at the time of the act. The medical certificates presented by appellant, which indicated a diagnosis of schizophrenia, were insufficient to prove he was insane at the precise moment of the killing. The Court emphasized that insanity must be proven by clear and convincing evidence, and the defense failed to meet this burden. Appellant’s claim of blacking out and inability to remember the incident did not constitute proof of insanity during the commission of the crime.
2. On the conviction for murder: The Supreme Court affirmed appellant’s conviction for murder. The Court found that the qualifying circumstances of treachery and abuse of superior strength were present. Treachery was established because the attack was sudden, rendering the victim defenseless and unaware. Abuse of superior strength was also appreciated as appellant, an adult male armed with a knife, employed force disproportionately against the unarmed victim. The positive identification by eyewitness Lyn Joy, who was consistent and credible, established appellant’s guilt beyond reasonable doubt. The Court modified the penalties and damages in accordance with prevailing jurisprudence, sentencing appellant to reclusion perpetua without eligibility for parole, and ordering him to pay civil indemnity, moral damages, exemplary damages, and temperate damages, all with legal interest.