PEOPLE v. RENEGADO May 31, 1974 (G.R. No.

L-27031)

PARTIES: plaintiff-appellee: THE PEOPLE OF THE PHILIPPINES
accused-appellant: LORETO RENEGADO y SENORA

FACTS:

Mamerto de Lira was a math teacher in Tiburcio Tancinco Memorial Vocational School which is run by the
national government. Loreto Renegado was a clerk in the same school. De Lira asked Renegado to type
his exam questions but the latter refused. They had a small argument which left the accused fuming with
anger. The accused told several people that hell gonna kill the deceased. They pacified him and told him
the possible consequences that may happen. After a few days, while the deceased was in the canteen
sitting with his back towards the accused, without warning the accused stabbed the deceased with a knife
which later caused the latters death. The counsel of the accused pleads for an acquittal on the ground that
the accused should be exempt from criminal liability because at the precise time he stabbed de Lira, the
accused lost his senses and he simply did not know what he was doing. His counsel claimed that after
Renegado was clubbed on the forehead, he suffered from head injury which produced ill-effects.


ISSUE(s):
(1) WON the accused is exempt from criminal liability on the ground of insanity.

(2) What are the mitigating and aggravating circumstances present in the case.

HELD:
(1) No. Insanity exists when there is a complete deprivation of intelligence in committing act, that is, the
accused is deprived of reason, he acts without the least discernment because there is a complete absence
of the power to discern, or that there is a total deprivation of freedom of the will, mere abnormality of the
mental faculties will not exclude imputability. In the case at bar, it just shows that Renegado is a man of
violent temper who can be easily provoked to violence for no valid reason at all. Thus in People vs. Cruz,
this Court held that breaking glasses and smashing dishes are simply demonstrations of an explosive
temper and do not constitute clear and satisfactory proof of insanity; they are indications of the passionate
nature of the accused.

In the absence of proof that the defendant had lost his reason or became demented a few moments prior to
or during the perpetration of the crime, it is presumed that he was in a normal condition of mind.

(2) The killing of Mamerto de Lira is qualified by evident premeditation. Here, the accused has more or less
sixty-four hours to ponder over his plan and listen to the advice of his co-employees and of his own
conscience, and such length of time was more than sufficient for him to reflect on his intended revenge.
There is treachery committed. There is treachery where the victim who was not armed was never in a
position to defend himself or offer resistance, nor to present risk or danger to the accused when assaulted.
The accused killed the deceased while he was eating and his back faced towards him.
There was an assault upon a person in authority. A teacher either of a public or of a duly recognized private
school is a person in authority.The mitigating circumstance of voluntary surrender was offset by the
aggravating circumstance of treachery.