People vs. Racal (2017)

PEOPLE OF THE PHILIPPINES vs. ROGER RACAL

G.R. No. 224886, September 4, 2017 

PERALTA, J.:

Facts: In an Information, Racal was charged with the crime of murder when the said accused, armed with a knife, with treachery, unexpectedly, attack and use personal violence upon the person of one Jose Francisco by stabbing the latter, at his body, thereby inflicting a fatal wound and as a consequence of which he died. The prosecution established that while the “trisikad” drivers were waiting for passengers, Racal told the group of drivers not to trust Francisco because he is a traitor. Francisco asked Racal why the latter called him a traitor. Without warning, Racal approached Francisco and stabbed him several times with a knife, hitting him in the chest and other parts of his body.

Racal did not deny having stabbed Francisco but he raised the defense of insanity contending that he has a predisposition to snap into an episode where he loses his reason and thereby acts outside his conscious control.

Issue: Whether or not the defense of insanity may be validly invoked.

Ruling: No, the defense failed to overcome the presumption of sanity. In the eyes of the law, insanity exists when there is a complete deprivation of intelligence in committing the act. The accused must be deprived of reason and act without the least discernment because there is a complete absence of the power to discern or a total deprivation of freedom of the will.

In the present case, the separate psychiatric evaluations of appellant were taken three and four years after the crime was committed. An inquiry into the mental state of an accused should relate to the period immediately before or at the very moment the felony is committed. On his part, Dr. Gerong testified that he found appellant to have “diminished capacity to discern what was wrong or right at the time of the commission of the crime.” “Diminished capacity” is not the same as “complete deprivation of intelligence or discernment.”

The Court, however, appreciated the mitigating circumstance of illness as would diminish the exercise of willpower of appellant without, however, depriving him of the consciousness of his acts, pursuant to Article 13, paragraphs 9 and 10 of the RPC.

Ratio Decidendi: In the absence of evidence to the contrary, the law presumes that every person is of sound mind and that all acts are voluntary.

Gist: Before the Court is an ordinary appeal filed by accused-appellant, Roger Racal, assailing the Decision of the Court of Appeals, which affirmed, with modification, the Decision of the Regional Trial Court (RTC) of Cebu City finding herein appellant guilty of the crime of murder.