People vs. Haloc y Codon

Insanity as an exempting circumstance under Article 12 of the Revised Penal Code requires complete deprivation of intelligence (cognition) and freedom of the will at the time of the commission of the criminal act, such that the accused acts without the least discernment; mere abnormality of mental faculties, psychosis, or diminished will power is insufficient to exempt from criminal responsibility.

Jessie Haloc y Codon, then fifty-one years old, resided in Barangay Union, Gubat, Sorsogon. He had a history of mental illness for which he received treatment at the Don Susano Memorial Mental Hospital in 2003 and 2007. In the weeks preceding June 22, 2008, his wife observed a recurrence of his mental disorder characterized by glazed eyes, inability to work, and failure to recognize her. Despite medical intervention in April 2008, Haloc was reportedly drinking alcohol and experiencing sleep disturbances due to noise from neighboring children.

• The Attack: On June 22, 2008, at approximately 12:00 noon, Jessie Haloc y Codon, armed with a 24-inch bolo, entered the yard of the de la Cruz family in Barangay Union, Gubat, Sorsogon. He initially attempted to hack the children's father, Ambrosio de la Cruz, who escaped. Haloc then turned his attention to Ambrosio's five sons who were following their father. He hacked Allan de la Cruz (9 years old) on the right arm, then seized Arnel de la Cruz (4 years old) and hacked him on the neck, severing the jugular veins and nearly decapitating him, resulting in instantaneous death.
• Mental History: Haloc had been previously treated for mental disorders. In 2003 and 2007, he was confined at the Don Susano Memorial Mental Hospital in Cadlan, Pili, Camarines Sur. In April 2008, his wife brought him to Dr. Gregorio, who prescribed medication that temporarily improved his condition. However, weeks before the incident, his wife observed a recurrence of symptoms including glazed eyes, inability to work, and failure to recognize her, prompting her to leave the house two days before the attack. His sister, Araceli Haloc-Ayo, testified that days before the incident, Haloc had been drinking alcohol due to insomnia over his child's upcoming wedding.
• Post-Attack Conduct: Immediately after the hacking, Araceli approached Haloc, who was standing by a trail. Despite his "blazing" eyes and fierce demeanor, Haloc recognized his sister and voluntarily surrendered the bolo to her.
• Medical Evidence: Dr. Imelda Escuadra, a psychiatrist from Don Susano Memorial Mental Hospital, confirmed Haloc's treatment history but testified that during his last consultation, his condition had improved and he no longer showed psychotic signs and symptoms. She did not categorically state that he was psychotic at the time of the offense, only that the medications prescribed were for psychosis. The prosecution did not present evidence.

• Complete Deprivation of Reason: Haloc argued that he was insane at the time of the commission of the crimes, having been completely deprived of reason and intelligence, and should therefore be exempt from criminal responsibility under Article 12 of the Revised Penal Code.
• Mitigating Circumstance of Illness: Alternatively, Haloc maintained that even if not completely insane, his mental condition constituted a mitigating circumstance under Article 14(9) of the Revised Penal Code, as his illness diminished his exercise of will power.

• Presumption of Sanity: The People countered that the law presumes every person to be sane, and Haloc failed to overcome this presumption with clear and convincing evidence.
• Lack of Complete Deprivation: The prosecution argued that insanity requires complete deprivation of intelligence and freedom of the will, not merely abnormality of mental faculties or psychosis; Haloc's ability to recognize his sister and surrender the weapon demonstrated he retained cognition and will.
• Treachery: The crimes were qualified by treachery because the victims were minor children (9 and 4 years old) who could not offer effective resistance against an adult assailant.

• Insanity as Exempting Circumstance: Whether Haloc proved by clear and convincing evidence that he was completely deprived of intelligence and freedom of will at the time of the commission of the crimes so as to be exempt from criminal liability under Article 12(1) of the Revised Penal Code.
• Mitigating Circumstance of Illness: Whether Haloc's mental condition constitutes a mitigating circumstance under Article 14(9) of the Revised Penal Code.

• Insanity as Exempting Circumstance: The defense was rejected. Insanity requires complete deprivation of intelligence (cognition) and freedom of the will at the exact time of the criminal act, such that the accused acts without the least discernment. Mere abnormality of mental faculties, psychosis, or a history of mental illness is insufficient. Haloc's post-crime conduct—recognizing his sister and voluntarily surrendering the weapon—demonstrated he was not totally deprived of reason. The medical evidence only established treatment for mental illness, not complete deprivation of intelligence at the time of the attack. The presumption of sanity thus prevailed.
• Mitigating Circumstance of Illness: The claim was rejected. No evidence was presented showing that Haloc's mental condition diminished the exercise of his will power at the time of the commission of the crimes.
• Treachery: The conviction for murder and attempted murder was affirmed. The killing of a child by an adult assailant is always treated as treacherous because the minor's tender age and relative weakness preclude effective resistance, eliminating risk to the attacker.
• Damages: Pursuant to People v. Jugueta, the awards were modified. For the murder of Arnel (Criminal Case No. 2781), civil indemnity, moral damages, and exemplary damages were each fixed at ₱75,000.00. For the attempted murder of Allan (Criminal Case No. 2780), civil indemnity, moral damages, and exemplary damages were each fixed at ₱25,000.00. All amounts shall earn interest at 6% per annum from the finality of the decision until full payment.

• Insanity as Exempting Circumstance — Under Article 12(1) of the Revised Penal Code, insanity exempts from criminal liability only when it involves complete deprivation of intelligence and freedom of the will at the time of the commission of the act. The test is whether the accused was deprived of reason, acted without the least discernment, and suffered total deprivation of freedom of will. Mere abnormality of mental faculties, psychosis, or mental illness short of complete deprivation does not exempt from liability. The defense is in the nature of confession and avoidance, shifting the burden to the accused to prove insanity by clear and convincing evidence.
• Presumption of Sanity — The law presumes every person to be sane; this presumption must be overcome by clear and convincing evidence to establish insanity as a defense.
• Treachery Against Minors — An attack by an adult against a minor child is deemed treacherous per se because the minor's tender age, small frame, and inexperience prevent effective resistance, ensuring the execution of the crime without risk to the assailant.
• Evidence of Insanity — Insanity may be shown by surrounding circumstances, general conduct, appearance, acts inconsistent with previous character, irrational beliefs, and medical evidence. Evidence must refer to the mental condition at the time of the act, though evidence for a reasonable period before and after is admissible.

• "To be exempting from criminal responsibility, insanity is the complete deprivation of intelligence in committing the criminal act. Mere abnormality of the mental faculties does not exempt from criminal responsibility."
• "Insanity, to be exempting, requires the complete deprivation of intelligence, not only of the will, in committing the criminal act."
• "The killing of or assault against a child by an adult assailant is always treated as treacherous, even if the treacherous manner of the assault is not shown."
• "The defense of insanity is thus in the nature of a confession or avoidance. The accused who asserts it is, in effect, admitting to the commission of the crime. Hence, the burden of proof shifts to him, and his side must then prove his insanity with clear and convincing evidence."

• People v. Dungo, G.R. No. 89420, July 31, 1991 — Discussed the criteria for determining insanity (delusion test, irresistible impulse test, right and wrong test) and cited Section 1039 of the Revised Administrative Code defining insanity; followed.
• People v. Jugueta, G.R. No. 202124, April 5, 2016 — Established the current rates for damages in murder cases (₱75,000.00 each for civil indemnity, moral damages, and exemplary damages); followed for the modification of damages.
• People v. Pantoja, G.R. No. 223114, November 29, 2017 — Affirmed that the defense of insanity shifts the burden to the accused to prove it with clear and convincing evidence; followed.
• People v. Sanchez, G.R. No. 188610, June 29, 2010 — Established that killing a child by an adult is always treacherous; followed.

• Article 12(1), Revised Penal Code — Exempts from criminal liability an imbecile or insane person, unless the latter acted during a lucid interval; applied to determine the standard for insanity.
• Article 14(9), Revised Penal Code — Provides that illness diminishing the exercise of will power is a mitigating circumstance; applied to reject the alternative claim for mitigation.
• Article 248, Revised Penal Code — Defines murder and enumerates qualifying circumstances including treachery; applied to affirm the convictions.
• Section 1039, Revised Administrative Code — Defines insanity as a manifestation of disease or defect of the brain characterized by perversion or disordered function of mental faculties; cited as a working definition.

Teresita J. Leonardo-De Castro (Chief Justice), Mariano C. Del Castillo, Francis H. Jardeleza, and Noel Gimenez Tijam.