G.R. No. 124453.

March 15, 2000

THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSEPH PAMBID y
CORNELIO, accused-appellant.
FACTS:
On January 24 1996, by virtue of Article 335 of the Revised Penal Code, the Regional
Trial Court ruled that Joseph Pambid was guilty beyond reasonable doubt for two
counts of rape of Marycon Delvie Grefaldia. Accused-appellant was sentenced to
suffer the penalty of Reclusion Perpetua with all the accessory penalties of the law
and to indemnify the complainant, the sum of P50, 000.00 plus costs for each count
of rape.
However, accused-appellant filed an appeal from the RTCs decision on the following
basis:
1. At some point, the victim stated in her testimony, that she was only
"fingered."
2. The mother of the accused claimed that her son was not in her house but in
the house of his father instead, when the first incident of rape allegedly
happened.
3. The parents of the accused contended that their son is exempt from criminal
liability by reason of insanity specifically suffering from schizophrenia and
mild mental retardation.
4. The trial court erred in its conviction of the accused-appellant while there was
just one (1) information filed against him.
ISSUE:

Whether or not accused-appellants claim of insanity exempts him from

criminal liability
Whether or not the RTC erred in the accused-appellants conviction for two
counts of rape

RULING:
No. The bare testimony of the accused-appellants parents that he had suffered
insanity was inadequate to prove that when he raped the victim he was completely
deprived of reason. Article 12 (1) of the Revised Penal Code provides that an
imbecile or insane person is exempt from criminal liability, unless he has acted
during a lucid interval, the presumption, under Art. 800 of the Civil Code, is that
every man is sane. Anyone who pleads the exempting circumstance of insanity
bears the burden of proving it, which he failed to discharge. Hence, by the totality of
the accused-appellants act as described by the victim, it showed that he was fully
conscious and aware of what he was doing.
Yes. The Regional Trial Court, in its decision, failed to consider, that accusedappellant could not have objected to the validity of the information or raise the
issue of duplicity of offenses since the information does not charge him with more

than one offense or occasion of rape. Thus, although it was shown that accusedappellant raped the victim on two occasions, nonetheless, he can be convicted for
one count of rape only.
WHEREFORE, the RTCs decision is SET ASIDE and another one is rendered finding
accused-appellant Joseph Pambid y Cornelio GUILTY of one (1) count of rape,
sentencing him to suffer the penalty of reclusion perpetua and ordering him to pay
complainant Maricon Delvie C. Grifaldia P50,000.00 as civil indemnity and
P50,000.00 as moral damages, plus costs.