G.R. No. 144505 - PEOPLE OF THE PHILIPPINES, VS. ERNESTO SAN JUAN Y DELA PEÑA, ACCUSED-.

Ruling

WHEREFORE, the accused, Ernesto San Juan, is hereby convicted of the crime of murder and sentenced to suffer the penalty of reclusion perpetua with all the accessory penalties provided by law and to pay the costs. On the civil liability of the accused, he is ordered to pay the legal heirs of the victim moral and nominal damages in the sum of P200,000.00 and P100,000.00, respectively, and compensation for the loss of the life of the victim in the amount of P50,000.00 with interest at the legal rate of 6% per annum from this date until fully paid. [6] The accused appealed the decision to this Court. But before filing his Brief, he filed a Motion to Remand Case to the Court a Quo for Further Reception of Defense Evidence. The PAO lawyers handling his case on appeal averred that while studying the case, they discovered that a Medical Certificate dated October 6, 1997 and prepared by Senior Inspector and Medical Officer Arthur G. Lorenzo of the Bureau of Jail Management and Penology was attached to the case records. It stated that accused San Juan was diagnosed to have R/O Schizophrenia. The medical certificate was not, however, formally offered by the last PAO lawyer who handled the case in the lower court. Neither was Dr. Lorenzo presented in court. Invoking substantial justice, the accuseds new PAO lawyers prayed for the remand of the case to the court a quo for further reception of evidence of the accuseds insanity at the time of the commission of the crime as his mental state would exempt him from liability. [7] The Solicitor General filed an Opposition to the Motion to Remand, pointing out that the medical certificate, even if admitted, would only prove the accuseds insanity when he was diagnosed on October 6, 1997, and not at the time the crime was committed on January 13, 1996. The Solicitor General argues that, in fact, the accused consciously admitted in court that he stabbed Bernardo Cortez with a knife on the date in issue allegedly in retaliation for hitting (punching) him on his forehead. . . Such admission indicates in clear terms that appellant understood the nature of his act and the consequences thereof. In short, the act was willfully, voluntarily and knowingly executed. [8] Finally, the Solicitor General avers that the Motion to Remand is procedurally flawed as it aims to reopen the case, but a motion to reopen a case is proper only after either or both parties have formally offered and closed their evidence, but before judgment. [9] The parties then filed their respective Briefs. The accused makes the following assignment of errors: I. THE TRIAL COURT GRAVELY ERRED IN FINDING ACCUSED-APPELLANT GUILTY BEYOND REASONABLE DOUBT OF THE CRIME OF MURDER DESPITE INSUFFICIENCY OF EVIDENCE FOR THE PROSECUTION. II. ASSUMING ARGUENDO, THAT ACCUSED-APPELLANT IS GUILTY, THE TRIAL COURT ERRED IN AWARDING DAMAGES WHICH ARE NOT ONLY EXCESSIVE BUT ARE BEREFT OF ANY FACTUAL AND LEGAL BASIS. [10] The Solicitor General correctly points out