People vs. Calines

The exempting circumstance of insanity must be proven by clear and convincing evidence to exist at the very moment the crime was committed, and a psychiatric evaluation conducted long after the fact, without corroborating evidence of the accused's mental state at the time of the offense, is insufficient to overturn the presumption of sanity.

Accused-appellant Fernan Calines y Magastino was charged with frustrated homicide and murder for attacking Nida Sabado and her three-year-old son, Sky Sabado, with a piece of wood on December 19, 2016. Sky died from his injuries four days later. Calines initially pleaded guilty but later changed his plea to not guilty and interposed the defense of insanity, claiming he suffered from schizophrenia.

• Nature of the Case: Two separate Informations were filed against Calines for frustrated homicide (for the attack on Nida Sabado) and murder (for the killing of her son, Sky Sabado).
• The Attack: On December 19, 2016, Calines entered a shanty where Nida and her three-year-old son Sky were resting. He struck Nida multiple times on the head and nape with a piece of wood, rendering her semi-conscious. He then forcibly dragged Sky outside.
• Discovery and Aftermath: Nida crawled to the road and was found by a neighbor, Tyler Tudayan, who recognized Calines from her description. Sky was found near the shanty and died four days later from severe traumatic brain injuries.
• Initial Plea and Change: Calines initially manifested an intent to plead guilty but later, after undergoing psychiatric evaluation, withdrew his guilty plea and pleaded not guilty, raising insanity as a defense.
• Defense Evidence: The defense presented a psychiatrist, Dr. Gamueda, who evaluated Calines in 2018 and diagnosed him with schizophrenia paranoid type. Calines's sister testified about his psychiatric hospitalization in 2014 and that he stopped medication in 2016.
• Lower Court Findings: The RTC found Calines guilty of frustrated homicide and murder, rejecting the insanity defense. The CA modified the frustrated homicide conviction to attempted homicide, affirming the murder conviction and the rejection of insanity.

• Insanity as an Exempting Circumstance: Petitioner argued that he was suffering from schizophrenia at the time of the commission of the crimes, which deprived him of reason and freedom of will, thus exempting him from criminal liability.
• Credibility of Psychiatric Evaluation: Petitioner maintained that the psychiatric evaluation report and the testimony of Dr. Gamueda sufficiently proved his insanity.

• Failure to Prove Insanity at the Time of the Crime: Respondent countered that the defense failed to prove by clear and convincing evidence that Calines was insane at the very moment the crimes were committed in 2016.
• Hearsay and Untimely Evidence: Respondent argued that the 2018 psychiatric evaluation was irrelevant to Calines's mental state in 2016, and the testimony regarding the 2014 diagnosis was hearsay since the evaluating physician was not presented.
• Consciousness of Guilt: Respondent pointed to Calines's act of fleeing after the crime as indicative of his awareness of the wrongfulness of his acts.

• Validity of the Convictions: Whether the CA erred in affirming Calines's conviction for murder and attempted homicide.
• Sufficiency of the Insanity Defense: Whether the defense of insanity was sufficiently proven to exempt Calines from criminal liability.

• Validity of the Convictions: The convictions were upheld. The killing of the three-year-old child was deemed qualified by treachery, as the victim's tender age rendered him inherently defenseless. The attack on the mother was correctly classified as attempted homicide because the prosecution failed to prove her wounds were fatal, and the crime was not attended by any qualifying circumstance.
• Sufficiency of the Insanity Defense: The defense of insanity was rejected. The three-way test for insanity from People v. Paña was not satisfied. The psychiatric evaluation in 2018 did not establish Calines's mental state in 2016. Testimony about a prior diagnosis was hearsay. Furthermore, Calines's conduct—fleeing after the crime and his behavior during arraignment—demonstrated he was not completely deprived of reason or discernment at the time of the offenses.

• Three-Way Test for Insanity — To successfully invoke insanity as an exempting circumstance, the defense must prove: (1) insanity was present at the time of the commission of the crime; (2) insanity, which is the primary cause of the criminal act, must be medically proven; and (3) the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act. The Court applied this test and found the evidence insufficient on all three counts.

• "Calines's mental condition two years after the crimes were committed is irrelevant for purposes of determining whether he was also insane when he committed the crimes in 2016."
• "Calines's attempt to flee after being asked by his brother where he took Sky indicates that he was fully aware of the nature and quality of the wrongfulness of his acts."

• People v. Paña, 890 Phil. 533 (2020) — Controlling precedent that established the three-way test for determining the validity of an insanity defense.
• People v. Jugueta, 783 Phil. 806 (2016) — Applied for the computation of civil indemnity, moral damages, exemplary damages, and temperate damages in cases of murder and attempted homicide.
• People v. Pilen, G.R. No. 254875 (2023) — Cited for the doctrine that the killing of a child of tender years is deemed ipso facto qualified by treachery.

• Article 248, Revised Penal Code — Defines murder and provides the penalty when attended by treachery.
• Article 6, Revised Penal Code — Defines an attempt to commit a felony.
• Article 12(1), Revised Penal Code — Provides that an insane person is exempt from criminal liability, unless acting during a lucid interval.
• Article 51, Revised Penal Code — Provides for the penalty to be imposed when the felony committed is only attempted.

• Senior Associate Justice Marvic M.V.F. Leonen (Chairperson)
• Justice Henri Jean Paul B. Inting
• Justice Ramon Paul L. Hernando
• Justice Jhosep Y. Kho, Jr. (Ponente)
• Justice Maria Filomena D. Singh