**818 Phil. 1002 (2017)**
## Facts
On January 2, 2004, PO2 Emelito Salen and SPO4 Onofre Tavas from the Rodriguez Police Station received a report regarding a fire in Sitio Catmon, Brgy. San Rafael, Rodriguez, Rizal. They arrived to find a burned house belonging to Mario Balbao y Adami. Inside the house was the burned body of a headless man. They received information from Willy Cacho that his brother, Wilson Cacho y Songco, was responsible for the crime. Wilson was later found and exhibited signs of mental illness, admitting to killing Mario and burning the house.
Wilson Cacho was charged with two crimes:
1. **Murder (Criminal Case No. 7522)**: For beheading Mario Balbao y Adami with qualifying circumstances of treachery, evident premeditation, and nighttime.
2. **Destructive Arson (Criminal Case No. 7523)**: For setting fire to Mario’s house to conceal the murder out of spite or hatred.
Wilson pleaded not guilty and raised the defense of insanity but was convicted by the RTC of San Mateo, Rizal. The Court of Appeals affirmed the conviction. Wilson then appealed to the Supreme Court.
## Issues
1. Whether the accused-appellant sufficiently proved his defense of insanity.
2. Whether the crimes of Murder and Destructive Arson were sufficiently proved.
## Court’s Decision
### Defense of Insanity
The Supreme Court ruled that Wilson Cacho failed to prove his insanity at the time of the commission of the crimes. Although diagnosed with Major Depression with Psychosis and later Chronic Schizophrenia, there was no evidence showing he was insane immediately before or during the crime. The Court held that previous confinement in a mental institution does not automatically establish insanity for criminal liability exemption.
### Conviction for Murder
The Supreme Court found that the elements of the qualifying circumstances, particularly treachery, evident premeditation, and nighttime, were not proved by the prosecution. The accused’s admission of the crime did not relieve the prosecution of its duty to prove these qualifying circumstances beyond a reasonable doubt. Consequently, Wilson Cacho’s conviction was reduced to Homicide.
### Conviction for Destructive Arson
The Court affirmed Wilson Cacho’s conviction for Destructive Arson. It was clear he burned Mario’s house to hide the evidence of the murder. Two separate crimes (Homicide and Destructive Arson) were committed, validating the lower courts’ decisions.
### Penalties
**For Homicide (Criminal Case No. 7522):**
– Indeterminate penalty of 8 years and 1 day of prision mayor as minimum to 17 years and 4 months of reclusion temporal as maximum.
– Ordered to pay Mario Balbao’s heirs P50,000.00 as civil indemnity and P50,000.00 as moral damages with 6% interest per annum from the finality of the decision until fully paid.
**For Destructive Arson (Criminal Case No. 7523):**
– Reclusion perpetua.
– Ordered to pay the heirs P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages with 6% interest per annum from the finality of the decision until fully paid.
## Doctrine
– **Insanity Defense**: An accused invoking insanity must prove with certainty that they were completely deprived of intelligence immediately before or during the crime.
– **Qualifying Circumstances**: These must be specifically alleged and proven beyond a reasonable doubt to elevate the crime to murder. Mere assertions without solid evidence do not suffice.
– **Separate Crimes**: Destructive Arson and Homicide/Murder can be charged separately if the initial crime is completed and arson is committed to conceal it.
## Class Notes
1. **Insanity Defense (Article 12, RPC)**: Only available if the accused proves complete deprivation of intelligence at the time of the crime.
2. **Qualifying Circumstances for Murder (Article 248, RPC)**:
– Treachery
– Evident premeditation
– Nighttime
– The prosecution must establish these circumstances beyond a reasonable doubt.
3. **Destructive Arson (Article 320, RPC)**: Malicious burning of structures with specific intents, resulting in separate liability in conjunction with other crimes like murder.
## Historical Background
The case arose within the societal context of mental health concerns and their legal implications. Wilson Cacho’s long-term mental health issues juxtaposed against the gravity of his crimes highlighted the need for robust legal scrutiny of insanity pleas and the requirement of substantial evidence to substantiate such defenses. It also underscored the rigorous standards necessary to qualify a lesser or higher degree of homicide under Philippine law.
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