G.R. No. 223114 - PEOPLE OF THE PHILIPPINES, VS. JONAS PANTOJA Y ASTORGA, ACCUSED-.DECISION - Supreme Court E-Library

Ruling

WHEREFORE , premises considered, Jonas Pantoja y Astorga is hereby found GUILTY beyond reasonable doubt of the crime of murder, defined and penalized under Article 248 of the Revised Penal Code and, there being no mitigating or aggravating circumstances, is hereby meted the penalty of reclusion perpetua without eligibility for parole conformably with Republic Act No. 9346. Accused is ordered to pay the heirs of [AAA] the amounts of P65,244.00 by way [of] actual damages, P75,000.00 as civil indemnity and P50,000.00 as moral damages. Interest at the rate of six percent (6%) per annum shall be applied to the award of all damages from the finality of the judgment until fully paid. [16] The RTC reasoned that all the pieces of evidence proffered by the defense are insufficient to warrant a finding that accused-appellant was insane at the time immediately preceding or simultaneous with the crime. Consequently, the presumption of sanity stands. Aggrieved, accused-appellant appealed before the CA. The CA Ruling The CA affirmed the conviction of the accused-appellant, with modification as to the award of damages. The dispositive portion of its decision reads as follows: WHEREFORE , the Decision of the Regional Trial Court of Pasig City, Branch 163, Taguig City Station, in Criminal Case No. 143350, is hereby AFFIRMED WITH MODIFICATION in that accused-appellant Jonas Pantoja y Astorga (JONAS) is ORDERED to pay actual damages in the amount of P35,000,00. [17] The CA agreed with the RTC that the evidence of the defense do not prove that accused-appellant was insane at the time he committed the crime. Furthermore, while the CA acknowledged that accused-appellant has a history of mental illness which diminished the exercise of his willpower without depriving him of the consciousness of his acts, it also ruled that this mitigating circumstance could not serve to lower the penalty meted against accused-appellant because reclusion perpetua is a single and indivisible penalty. Hence, this appeal. ISSUE This Court is tasked to determine whether accused-appellant has clearly and convincingly proven his defense of insanity to exempt him from criminal liability and, in the negative, whether his mental issues constitute diminished willpower so as to mitigate his liability and to lower the penalty. THE COURT'S RULING After a careful evaluation of the records, this Court sees no reason to overturn the decision of the CA, except to modify the amount of damages awarded. The defense of insanity is in the nature of a confession and avoidance, requiring defendant to prove it with clear and convincing evidence. The RTC and the CA both found that all the elements constituting murder exist in the case at bar, with accused-appellant as the perpetrator. The accused-appellant did not present evidence controverting such findings. However, accused-appellant raises the defense of insanity in claiming that he should not be found criminally liable. Insanity is one of the exempting circums