People v.

ESTRADA
G.R. No. 130487,June 19, 2000
FACTS: In the morning of Dec. 27, 1994 while the Bishop of Dagupan City was performing
confirmation rites on children in St. John's Cathedral, Dagupan, accused-appelant Roberto
Estrada approached the altar and sat on the Bishop's chair refusing to vacate. The victim,
security guard Rogelio Mararac, asked the accused to move but to no avail. Mararac asked the
appellant again while tapping the latter's hand with a nightstick then all of a sudden the latter
lunged at the victim and stabbed him below his left throat and left arm. Then after, the appellant
stood up and shouted through the microphone that no one can beat him and sat again on the
Bishop's chair. The victim died a few minutes after being brought to the hospital. The appellant
was charged with murder. On two separate occassions during the course of the trial, the Jail
Warden of Dagupan City requested the trial court to allow the appellant to be mentally examined
and treated to determine whether he should remain or be transferred to some other institution.
The appellant's counsel filed a motion to confine the accused for physical, mental and psychiatric
examination and also presented evidence that the accused has been confined at Baguio General
Hospital due to schizophrenia for 4 days in 1993. The trial court denied the motion and convicted
the appellant of the crime of murder with the sentence of death.
ISSUE: WON accused-appellant is guilty beyond reasonable doubt despite clear evidence
supporting his plea of insanity
HELD: The basic principle in our criminal law is that a person is criminally liable for a felony
(Art.4) presuming that the felonious or criminal act was done by a person, of sound mind,
voluntarily. the accused has the burden to prove by clear and positive evidence that there is
insanity, invoked as an exempting circumstance, during the time immediately preceding the act or
at the very moment of its execution. The trial court should have considered that the appellant may
not have been in full possession of his mental faculties when he attacked Mararac. It's very
unusual for a person of right mind to do what the appellant did in that cathedral.The court should
have also took notice of the appellant's history of mental illness and not just rely on the intelligent
answer by the latter since this is not a conclusive evidence that he was competent enough to
stand trial and assist in his defense.The RPC violated a basic requirement of due process when it
deprived appellant a mental examination and thus effectively depriving appellant a fair trial. The
case is remanded to the court a quo.