G.R. Nos. L-55033-34 November 13, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO ALDEMITA y MALIHAN, defendant-appellant.

FACTS

The case involves the automatic review of the death penalty imposed by the Circuit Criminal Court of Manila on Renato Aldemita for the crimes of murder and frustrated murder. The appellant was convicted for the killing of his superior, Erlinda Viardo, a managing partner at the accounting firm where he worked, and for the wounding of her secretary, Angelita Yambao. The prosecution’s evidence established that on March 5, 1976, Aldemita entered Viardo’s office, locked the door, and attacked Yambao with a jungle bolo before turning on Viardo and hacking her multiple times. Yambao managed to escape, but Viardo sustained twenty-five wounds and died at the scene. Aldemita surrendered to the police, to whom he admitted having planned the killing and purchased the bolo in advance.
At trial, Aldemita did not contest the commission of the acts. His sole defense was that he was insane at the time of the crimes and therefore should be exempt from criminal liability. To support this, the defense presented testimonies from his family describing his peculiar behavior and a psychiatrist who diagnosed him with schizophrenia. The prosecution countered with testimonies from co-workers and a company physician who stated that Aldemita had been performing his duties normally and showed no signs of insanity prior to the incident.

ISSUE

The core issue is whether the defense of insanity was sufficiently proven to exempt Aldemita from criminal responsibility for the crimes of murder and frustrated murder.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court rejected the defense of insanity, holding that it was not established by clear and convincing evidence. The legal logic rests on the presumption of sanity under Article 800 of the Civil Code. An accused claiming insanity must prove, by a preponderance of evidence, that they were completely deprived of intelligence or freedom of will at the precise moment of committing the crime. Mere abnormality of mind or eccentric behavior is insufficient; the required condition is a complete deprivation of reason.
The Court found the defense evidence wanting. The testimonies of family members, while describing strange conduct, did not conclusively prove a total loss of cognitive faculties. Crucially, the appellant’s actions before, during, and after the crime demonstrated planning, awareness, and control. He purchased the weapon days in advance, locked the door to prevent escape or intervention, immediately surrendered when assured of his safety, and gave a coherent account of his premeditation to the police. These facts indicated a consciousness of his actions and their consequences, wholly inconsistent with a complete absence of reason. The trial court correctly appreciated treachery and abuse of superior strength as qualifying and aggravating circumstances, respectively. However, for lack of the necessary votes, the death penalty for murder was reduced to reclusion perpetua, and the civil indemnity was increased to P30,000.00. The judgment for frustrated murder was affirmed.