G.R. No. 267795 , April 15, 2024
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JOSE P. RAGUDO, JR., ACCUSED-APPELLANT.

FACTS

Accused-appellant Jose P. Ragudo, Jr., a gatekeeper, was charged with Murder, Qualified Theft, and Alarms and Scandals for events on March 21, 2014. The informations alleged that he stabbed Nancy Cacayorin to death with treachery and abuse of superior strength, stole a Baby Armalite rifle from their employer, Go Group of Companies, and fired the stolen rifle in the company compound. Due to his unusual behavior in detention, the RTC granted a motion for psychiatric evaluation. The National Center for Mental Health (NCMH) diagnosed Ragudo with Schizophrenia but initially found him competent to stand trial. After arraignment where he pleaded not guilty, a reverse trial was conducted due to his insanity defense. The NCMH later issued a supplemental report opining that Ragudo was insane at the time of the crime, as his symptoms caused him to fail to appreciate the nature and wrongfulness of his acts. During trial, prosecution witnesses testified: Mark Anthony Rambaud confirmed the theft of the rifle; Chita Sacbibit saw Ragudo firing a gun; and Charmaine Salvador witnessed Ragudo repeatedly stabbing the seated and defenseless victim, Cacayorin. The testimonies regarding the victim’s death and funeral expenses were stipulated. The RTC convicted Ragudo of murder and theft, rejecting the insanity defense due to lack of conclusive evidence of complete deprivation of intelligence. The CA affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s judgment which convicted accused-appellant of murder and theft, thereby rejecting his defense of insanity.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the CA decision with MODIFICATIONS. The Court upheld the conviction for Murder and Simple Theft. The defense of insanity was rejected. The Court ruled that the defense failed to prove with clear and convincing evidence that Ragudo was completely deprived of intelligence or freedom of will at the exact time of the crime’s commission. The NCMH report, while noting his condition, was not conclusive on his state during the criminal act, especially given the testimony of a witness who interacted with him normally shortly before the incident. The qualifying circumstances of treachery and abuse of superior strength were present in the murder, as the attack was sudden and on a defenseless, seated victim. However, the theft conviction was modified from Qualified Theft to Simple Theft because the information did not allege the element of grave abuse of confidence necessary for qualification. The Court awarded civil indemnity, moral damages, exemplary damages, and temperate damages to the victim’s heirs, with interest. The penalty for Simple Theft was also modified in accordance with the Indeterminate Sentence Law.