Remedial Law Case Digest: People vs Rodolfo Villa, Jr

PEOPLE OF THE PHILIPPINES
vs.
RODOLFO VILLA, JR. y DELGADO

G.R. No. 129899

April 27, 2000

Facts:

Accused was charged with multiple murder. Before the defense could present its evidence, however, counsel de oficio manifested his inability to confer with the accused but moved that a psychiatric examination of the accused be made to determine his mental condition. The motion was granted. After more than a month of psychiatric evaluation, the attending physicians submitted tot he trial court a psychiatric evaluation report, which stated that accused was suffering from Insanity or Psychosis classified as Schizophrenia and that the accused is at that time incompetent to stand trial. When accused’s status had improved enough for him to withstand the rigors of the trial, trial resumed, with the accused now raising insanity as a defense. The trial court convicted the accused of the crime charged.

Issue:

Whether the accused’s defense of insanity was properly pleaded.

Held:

No. It could be that accused was insane at the time he was examined at the center. But, in all probability, such insanity was contracted during the period of his detention pending trial. Hwe was without contact with friends and relatives most of the time. He was troubled by his conscience, the realization of the gravity of the offenses and the thought of a bleak future for him. The confluence of these circumstances may have conspired to disrupt his mental equilibrium. But, it must be stressed, that an inquiry into the mental state of accused-appellant should related to the period immediately before or an inquiry into the mental state of the accused should relate to the period immediately before or at the precise moment of doing the act which is the subject of the inquiry, and his mental condition after that crucial period or during the trial is inconsequential for purposes of determining his criminal liability. In fine, the Court needs more concrete evidence on the mental condition of the person alleged to be insane at the time of the perpetration of the crimes in order that the exempting circumstance of insanity may be appreciated in his favor. The accused miserably failed to discharge the burden of overcoming the presumption that he committed the crimes freely, knowingly and intelligently.