Turalba y Villegas v. People, G.R. No. 216453, [March 16, 2022]

 CASE DIGEST

Turalba y Villegas v. People

 G.R. No. 216453, [March 16, 2022]

THIRD, LOPEZ, M.V

 

Carnapping; Psychosis as Mitigating Circumstance; Insanity Defense 

Anyone who pleads insanity bears the burden to prove it with clear and convincing evidence since the accused invoking the affirmative defense admits to have committed the crime, but claims that he or she is not guilty because of insanity. The burden of proof on the issue of insanity rests on the accused, and mere abnormality of mental faculties is insufficient to exclude imputability. With respect to mitigating circumstance, insanity was recognized only when there was a showing of some impairment of mental faculties but not a complete loss of intelligence or consciousness.

 

Oligario was charged with carnaping for stealing a 1996 model CRV Honda Wagon belonging to Gregorio Calimag. The incident occurred on November 20, 2007, in Olongapo City. Oligario pleaded not guilty, and during the trial, the prosecution presented evidence, including testimonies establishing the elements of the crime. Oligario raised the defense of insanity, supported by the testimony of Dr. Ma. Lourdes Labarcon Evangelista, who assessed him with psychosis due to alcohol and methamphetamine use. In defense, Dr. Evangelista testified and narrated that she first met Oligario on October 24, 2007 at the Mariveles Mental Hospital for evaluation and management of his mental condition. After tests, Dr. Evangelista assessed Oligario with psychosis ("nawawala sa sarili") due to use of alcohol and methamphetamine. She prescribed medication and scheduled a follow-up checkup, but Oligario was not able to come back as he was already detained for the carnapping incident. Oligario contends that his mental condition should either completely absolve him of criminal liability or, at the very least, be considered as a mitigating circumstance. The Regional Trial Court (RTC) convicted Oligario, finding all elements of carnaping present, while the CA affirmed the conviction, rejecting the insanity defense. The case involves the petition for review on certiorari challenging the decision in convicting Oligario for Carnapping. 

 

Whether or not Oligario's alleged insanity is a valid defense for Carnapping in this case. 

NO. The Supreme Court denied Oligario's petition for lack of merit. The Court held that Oligario failed to establish his mental state, particularly his insanity, with clear and convincing evidence. The burden of proof on the issue of insanity rests on the accused, and mere abnormality of mental faculties is insufficient to exclude imputability. Thus, the accused must prove the following: first, that the insanity constitutes a complete deprivation of intelligence, reason, or discernment; and second, the insanity existed at the time of, or immediately preceding, the commission of the crime.

The Court stressed that Oligario did not present witnesses or evidence to demonstrate his abnormal or bizarre behavior immediately before or simultaneous with the commission of the crime. The Court rejected Oligario's insanity defense considering that the manner by which he perpetrated the offense suggests full consciousness of his criminal act. Dr. Evangelista's medical assessment was rendered inconclusive and insufficient proof of the mental condition of Oligario. While Oligario asserted insanity, the Court found it insufficient to warrant exemption from criminal liability.

Regarding the argument for considering insanity as a mitigating circumstance, Oligario failed to establish his mental state, much less his insanity. As held in jurisprudence, insanity was recognized as a mitigating circumstance only when there was a showing of some impairment of mental faculties but not a complete loss of intelligence or consciousness. While it can be true that there was some impairment of Oligario's mental faculties, due to psychosis, the Court held that such impairment was not so complete as to deprive him of his intelligence or the consciousness of his acts.

Moreover, Oligario was charged with violation of RA No. 6539, a special law, which is not governed by the rules of penalties under the RPC. The penalty imposed by the RTC and affirmed by the CA, based on the Indeterminate Sentence Law, was deemed correct. Consequently, Oligario was found guilty of Carnapping and sentenced to an indeterminate penalty of fourteen (14) years and eight (8) months, as minimum, to seventeen (17) years and four (4) months, as maximum. 

 

 

 

 CLICK TO READ FULL TEXT