67. People vs.

Valledor - July 3, 2002

129291 - 383 SCRA 653
APPEAL from a decision of the Regional Trial Court of Puerto Princesa City, Br. 47.

FACTS:

This case is about Enrico Valledor’s appeal of his conviction for the crime of consummated, frustrated and attempted
murder. Last 06 March 1991, the appellant attacked Roger Cabiguen (stabbed on the forearm), Elza Rodriguez (stabbed
on the chest), Ricardo Maglalang (was inflicted w/ physical injuries on different parts of the body) There were two other
people inside the room (they were not harmed by the appellant). Roger and Ricardo were both wounded, while Elza
died from the stab wound. After his arrest, accused-appellant was intermittently confined at the National Center for
Mental Health. Thus, he was arraigned only on February 19, 1993 wherein he pleaded not guilty. Thereafter, the cases
were archived until November 15, 1994, when accused-appellant was declared mentally fit to withstand trial. This time,
accused-appellant admitted commission of the crimes charged but invoked the exempting circumstance of insanity.

The appellant’s plea of insanity was anchored on the following instances:

1.) On January 1990 the Mother of the appellant noticed that he is behaving abnormally. The mother then brought the
appellant to Dr. de Guzman, a medical practitioner. She then disclosed to the doctor that insanity runs in the family

2.) Dr. de Guzman then diagnosed the appellant as suffering from “psychosis w/ schizophrenia” and prescribed the
appellant w/ an anti-depressant known as thoracin which kept the appellant sane for a period of 2 months

3.) On 04 March 1991, the appellant’s mother noticed that he is acting strangely, so she left to buy Thoracin, but when
she returned the appellant is nowhere to be found.

4.) On 06 March 1991 (date of commission of crime) he was seen swimming across the river Barangay Captain and
Councilman took the appellant out of the water inside the boat, accused-appellant kept on crying and uttering words to
the effect that his family will be killed. Suspecting that appellant was mentally ill, the Barangay Captain, asked the
Councilman to accompany accused-appellant to Puerto Princesa City. Sibunga acceded and thereafter took a jeepney
with appellant, while on the jeepney the appellant then jumped off the jeepney and boarded a tricycle.

5.) On 11 March 1991 he was interviewed by the City Health Officer I and was recommended to be committed to the
NATIONAL MENTAL HOSPITAL

6.) While under the care of the hospital the medical findings for the appellant was that he was suffering from: Psychosis
or Insanity classified under Schizophrenia

ISSUE AND RULING:

Can Insanity as an exempting circumstance be granted to the accused? NO

1. Criminal Law; Murder; Exempting Circumstance; Insanity; The law presumes all acts to be voluntary and it is

improper to presume that acts were done unconsciously.-

In considering a plea of insanity as a defense, the starting premise is that the law presumes all persons to be of sound
mind. Otherwise stated, the law presumes all acts to be voluntary, and it is improper to presume that acts were done
unconsciously.

2. Criminal Law; Murder; Exempting Circumstance; Insanity; A man may act crazy but it does not necessarily and
conclusively prove that he is legally so; What is decisive is his mental condition at the time of the perpetration of the
offense.-

1
67. People vs. Valledor - July 3, 2002
129291 - 383 SCRA 653
Accused-appellant’s acts prior to the stabbing incident to wit: crying; swimming in the river with his clothes on; and
jumping off the jeepney; were not sufficient to prove that he was indeed insane at the time of the commission of the
crime. As consistently held by this Court, “A man may act crazy but it does not necessarily and conclusively prove that he
is legally so.” Then, too, the medical findings showing that accused-appellant was suffering from a mental disorder after
the commission of the crime, has no bearing on his liability. What is decisive is his mental condition at the time of the
perpetration of the offense. Failing to discharge the burden of proving that he was legally insane when he stabbed the
victims, he should be held liable for his felonious acts.

**- The acts made by the appellant shows that he does not have complete absence of the power to discern as shown by
his stabbing of the two victims (roger and elza) while leaving the other two people in the room unharmed, also his action
of fleeing from the scene after the incident indicated that he was aware of the wrong he committed.

**-- Although it can be argued that the appellant is suffering from mental illness what is decisive is his mental condition
at the time of the perpetration of the offense. Failing to discharge the burden of proving that he was legally insane when
he stabbed the victims, he should be held liable for his felonious acts.

HELD:

THE COURT FOUND THE ACCUSED GUILTY WITH MODIFICATIONS: HE IS GUILTY OF THE CRIME OF MURDER FOR THE
KILLING OF ELZA RODRIGUEZ, AND ATTEMPTED MURDER FOR BOTH ROGER CABIGUEN AND ROGELIO MAGLALANG
(FROM FRUSTRATED MURDER FOR INJURIES CAUSED TO MAGLALANG IT WAS REDUCED TO ATTEMPTED MURDER)