G.R. No. 225599 - PEOPLE OF THE PHILIPPINES, VS. CHRISTOPHER MEJARO ROA, ACCUSED-.

Ruling

WHEREFORE, premises considered, judgment is rendered finding accused Christopher Mejaro Roa GUILTY beyond reasonable doubt of the crime of Murder defined and penalized under Article 248 of the Revised Penal Code, and imposing upon him the penalty of reclusion perpetua. Accused is ordered to pay the Heirs of Eliseo Delmiguez the following sums: (1) P75,000.00 as civil indemnity for the death of said victim; (b) P50,000.00 as moral damages; and (c) P30,000.00 as exemplary damages. Aggrieved, accused-appellant appealed his conviction to the CA. The Ruling of the CA In its presently assailed Decision, the CA affirmed the finding of conviction by the trial court. The CA first noted that all the elements of the crime of murder had been sufficiently established by the evidence on record. On the other hand, the defense of insanity was not sufficiently proven by clear and convincing evidence. The CA said: Record shows that the accused-appellant has miserably failed to prove that he was insane when he fatally stabbed the victim on March 16, 2007. To prove his defense, accused-appellant's witnesses including Dr. Edessa Padre-Laguidao testified that they knew him to be insane because he was brought and confined to the Bicol Medical Center, Department of Psychiatry for treatment in the year 2001. However, such fact does not necessarily follow that he still suffered from schizophrenia during the time he fatally attacked and stabbed the victim, Eliseo Delmiguez. No convincing evidence was presented by the defense to show that he was not in his right mind, or that he had acted under the influence of a sudden attack of insanity, or that he had generally been regarded as insane around the time of the commission of the acts attributed to him. An inquiry into the mental state of the accused should relate to the period immediately before or at the very moment the act under prosecution was committed. Mere prior confinement in a mental institution does not prove that a person was deprived of reason at the time the crime was committed. It must be noted that accused-appllant was discharged from the mental hospital in 2002, or long before he committed the crime charged. He who relies on such plea of insanity (proved at another time) must prove its existence also at the time of the commission of the offense. This, accused-appellant failed to do. [7] (citations ommitted) Moreover, the CA ruled that the testimonies of the defense witnesses that purport to support the claim of insanity are based on assumptions, and are too speculative, presumptive, and conjectural to be convincing. To the CA, their observation that accused-appellant exhibited unusual behavior is not sufficient proof of his insanity, because not every aberration of the mind or mental deficiency constitutes insanity. [8] On the contrary, the CA found that the circumstances of the attack bear indicia that the killing was done voluntarily, to wit: (1) the use of a long bolo locally known as ginunting, (2) the loc