BATANGAS STATE UNIVERSITY
HUMAN BEHAVIOR AND VICTIMOLOGY
Project: Research on Insanity Defense in the Philippines (Case
Digest)
Name of Student: DEQUINA, GLENMARC D.
Instructor: DR. Fredda H. Ebanada
Case Title: G.R. No. 129899 PEOPLE OF THE PHILIPPINES, plaintiff-
appellee, vs.
RODOLFO VILLA, JR. y DELGADO, accused-appellant.
Date of Promulgation: April 27, 2000
The Facts
RODOLFO VILLA, JR. Y DELGADO appeals from the Decision of the trial court
convicting him of four (4) separate crimes of Murder qualified by treachery
and sentencing him to reclusion perpetua for each murder. He was also
ordered to indemnify the heirs of his four (4) victims in the amount of
P50,000.00 for each group of heirs or a total of P200,000.00.
The events are as follows:
June 22, 1991in the morning when Dionito was cutting grass in his yard in
New Cabalan, Olongapo City. Dionito’s neighbor, Rodolfo Villa Jr, a member
of the CAFGU suddenly came out of his house carrying a M-1 Garand rifle and
shot Dionito from behind that causes his instant death. Dionito’s children
namely Ronald Fernandez and Sheila Fernandez, rushed to their father's
rescue after hearing the gunshot but the accused also shot them. Samuel
Eclevia, another neighbor of the Fernandezes, attempted to get the gun from
the accused and wrestled him but Eclevia was shot too.
After his rampage, Rodolfo Villa Jr. surrendered to a certain Captain Dolino of
S2 OMDC (Olongapo Metropolitan District Command). Rodolfo was
accordingly charged with multiple murder.
Court’s Ruling
Meanwhile, on 16 July 1992, the trial court issued an order appointing Atty.
Romeo Alinea as counsel de oficio for the accused, as his counsel de
parte Atty. Cipriano Dumpit was unavailable due to his ongoing medical
treatment. Before the defense could present its evidence, however,
counsel de oficio Alinea manifested his inability to confer with the accused
but moved that a psychiatric examination of the accused be made at the
National Center for Mental Health to determine his mental condition. The
motion was granted and the accused was examined at the Olongapo City
General Hospital to ascertain whether he was suffering from mental illness
before, during and after the commission of the crimes.
Dr. Romeo Enriquez, the examining psychiatrist at the Olongapo City General
Hospital, recommended that the accused be confined at the National Center
for Mental Health, Forensic Pavillion, where while in the facility, an evaluation
process for the possibility of insanity is conducted. Thus, on 4 November
1994, the accused was confined and treated at the National Center for
Mental Health, under the direct supervision of Dr. Celeste A. C. Peña, Medical
Officer III, and Dr. Isagani S. Gonzales, Medical Specialist II, Physician-in-
charge Male Court Case Pavillion.
After more than a month of psychiatric evaluation, the attending physicians
submitted to the trial court a psychiatric evaluation report, which stated in
part —
PSYCHIATRIC EVALUATION RESULTS:
” Evaluation shows that the patient is suffering from Insanity or
Psychosis classified as Schizophrenia. This is a mental illness
characterized by deterioration in social and occupational functioning,
auditory hallucination, delusion, thought disturbances and poor
judgment. He is at present incompetent to stand trial.”
Six (6) months later, or on 5 June 1995, a follow-up report on the patient's
psychiatric status was made, this time by Dr. Cheryl Zalsos, with remarks
that the patient's status had improved enough for him to withstand the
rigors of the trial. Thus, Adoracion Manuit, Officer-in-Charge of the Legal
Section, National Center for Mental Health, filed a Petition for
Release praying that the accused be discharged and returned to jail for the
speedy disposition of his case, and further recommending that he be allowed
to undergo periodic check-up to sustain his improved mental state as well as
to prevent a relapse of his illness. 10 In its Order of 21 June 1995 the trial
court granted the petition and the trial resumed with the accused now
raising insanity as a defense.
On 3 April 1997 the trial court denied the defense of the accused and not
convinced that the accused is in sound mind during and before the
commission of the crime.
Issue
The only issue that exists in the case is that if the accused is insane during
the commission of the crime.
Insanity exists when there is complete deprivation of intelligence while
committing the act, i.e., the accused is deprived of reason, he acts without
the least discernment because there is complete absence of power to
discern, or that there is total deprivation of freedom of the will. Mere
abnormality of the mental faculties is not enough, especially if the offender
has not lost consciousness of his acts.
Concluding that the accused was insane during the commission of the crime
is not acceptable because in it impossible for the insane person to describe
the sequence of the crime clearly and making his Sworn Statement.
Moreover, if we were to follow accused-appellant's narration of the incident
in his Sworn Statement, it is shown that Dionito was accused by is neighbor
of stealing chickens and cursing at him making him rage. And it is known
that sometimes, people tend to do things because of rage and that does not
mean he/she is insane.
The law presumes every man to be of sound mind. Otherwise stated, the law
presumes all acts to be voluntary, and that it is improper to presume that
acts were done unconsciously. Thus, a person accused of a crime who pleads
the exempting circumstance of insanity has the burden of proving it. Insanity
is a defense by way of confession and avoidance, and as such the quantum
of evidence required to prove that is clear and convincing evidence.
WHEREFORE, the assailed Decision of the trial court convicting accused-
appellant RODOLFO VILLA, JR. Y DELGADO of four (4) separate counts of
Murder is AFFIRMED, subject to the MODIFICATION of the penalties imposed;
consequently, accused-appellant is sentenced to an indeterminate prison
term of ten (10) years two (2) months and ten (10) days of prision
mayor maximum, as minimum, to seventeen (17) years, six (6) months and
twenty (20) days of reclusion temporal maximum as maximum, for each
crime of murder. He is further ordered to INDEMNIFY the heirs of his victims
in the amount of P50,000.00 in each case or for a total of P200,000.00. Costs
against accused-appellant.
SO ORDERED.
Mendoza, Quisumbing, Buena and De Leon, Jr., JJ., con
Annotated Bibliography
Citation
Arieti, S. (1974). Interpretation of Schizophrenia (First Edition). Basic Books,
Inc.
This book in published specially for psychiatrist who studies psychoanalytic
oriented psychotherapy to treat patients. It is also intended for physicians
that works on advanced cases related to the psychoanalysis. In the book, the
author examines the relation of family history of people with schizophrenia.
From this examination, he supports the notion that the probability to develop
schizophrenia, has a genetic basis. The author acknowledges indebtedness
to the faculty of the William Alanson White Institute of New York. The
sections devoted to psychodynamics and treatment of schizophrenia show
the influence of Sullivan and Fromm-Reichmann. This reviewer prefers to
read the original writings of those authors. Arieti shows little or no interest in
current psychoanalytic concepts of ego psychology. He refers
to interpretation of genetic and dynamic factors but does not reveal how he
actually makes such interpretation.
References
Arieti, S. (1974). Interpretation of Schizophrenia (First Edition). Basic Books,
Inc.
G.R. No. 129899. (2000, April 27). Lawphil.Net.
https://lawphil.net/judjuris/juri2000/apr2000/gr_129899_2000.html
Bellak, L., & Benedict, P. K. (2010). Schizophrenia: A Review Of The
Syndrome V1. Kessinger Publishing, LLC.
People vs Villa Jr : 129899 : April 27, 2000 : J. Bellosillo : Second Division.
(2000). Https://Www.Chanrobles.Com/.
https://www.chanrobles.com/scdecisions/jurisprudence2000/apr2000/1
29899_apr2000.php
