In the case of People of the Philippines vs. Alberto Condino, the Supreme Court affirmed the conviction of Alberto Condino for murder, emphasizing that to be exempt from criminal liability due to insanity, the accused must prove a complete deprivation of intelligence at the time the crime was committed. The Court found insufficient evidence to support Condino’s claim of insanity during the act, highlighting the importance of establishing the accused’s mental state immediately before or during the commission of the offense. This ruling underscores the stringent requirements for invoking the insanity defense and clarifies the timeline for assessing an accused’s mental state.

The Basketball Game, the Gulukan, and the Question of a Mind: Did Mental Illness Excuse Murder?

The narrative unfolds in Barangay Canda, Sariaya, Quezon, on December 29, 1989. What began as a basketball game among friends turned deadly. Alberto Condino, allegedly under the influence of liquor, challenged Alejandro Magadia to a one-on-one match. The situation escalated when Condino, armed with a “gulukan”, chased Magadia. Later that day, Condino attacked Magadia, hitting him with a stone and stabbing him multiple times, leading to Magadia’s death. Condino’s defense hinged on his mental state, claiming insanity at the time of the incident and self-defense. The central legal question was whether Condino’s alleged insanity could exempt him from criminal liability, and if not, whether he acted in self-defense.

Condino’s defense invoked Article 12 of the Revised Penal Code (RPC), which states that “an imbecile or an insane person” is exempt from criminal liability unless they acted during a lucid interval.

ART. 12. Circumstances which exempt from criminal liability.-The following are exempt from criminal liability:

1. An imbecile or an insane person, unless the latter has acted during a lucid interval.

The defense argued that because Condino had been confined at the National Center for Mental Health and diagnosed with psychosis, his mental illness existed at the time of the killing. Therefore, he should be exempt from criminal liability. However, the Supreme Court rejected this argument, asserting that the critical point is whether Condino was completely deprived of intelligence at the moment he committed the crime. The court referenced People v. Austria, which emphasizes that evidence of insanity must directly relate to the period before or during the act.

We have stated that when insanity of the defendant is alleged as a ground of defense or reason for his exemption from responsibility, the evidence on this point must refer to the time preceding the act under prosecution or at the very moment of its execution. In such case, it is incumbent upon defendant’s counsel to prove that his client was not in his right mind or that he acted under the influence of a sudden attack of insanity or that he was generally regarded as insane when he executed the act attributed to him. In order to ascertain a person’s mental condition at the time of the act, it is permissible to receive evidence of his mental condition during a reasonable period before and after. Direct testimony is not required nor are specific acts of disagreement essential to establish insanity as a defense. A person’s mind can only be plumbed or fathomed by external acts. Thereby his thoughts, motives and emotions may be evaluated to determine whether his external acts conform to those of people of sound mind. To prove insanity, clear and convincing circumstantial evidence would suffice.

The Court noted that the law presumes sanity, placing the burden on the accused to prove insanity. While Condino was indeed observed to be mentally unsound during his scheduled arraignment and subsequently confined for treatment, this did not automatically imply that he was psychotic at the time of the crime. The defense failed to provide evidence showing Condino’s insanity immediately before or during the infliction of the fatal wounds. The prosecution, however, presented evidence suggesting that Condino had waited for the victim and then fled the scene, indicating a level of awareness inconsistent with complete insanity.

The testimonies of prosecution witnesses Felipe Mojica and Marcelino Cabutihan were crucial in establishing Condino’s guilt. Mojica testified that Condino challenged Magadia to a basketball game, then chased him with a “gulukan”, and later stoned and stabbed him. Cabutihan corroborated this, stating that Condino blocked their way, stoned the victim, and stabbed him while he was on the ground. The defense attempted to discredit these witnesses by pointing out inconsistencies in their testimonies, such as discrepancies in the number of wounds and the location of the dance party.

The Supreme Court dismissed these inconsistencies as minor details that did not negate the fact that Condino killed Magadia. Citing People v. Tulop, the Court reiterated that inconsistencies in minor details do not affect the veracity or weight of the witnesses’ declarations. The Court found the eyewitness accounts credible and consistent in their essential details.

The defense also questioned the decision of the trial judge, Judge Ismael Sanchez, to give weight to the prosecution’s testimony because he was not the presiding judge when the evidence was presented. The Supreme Court rejected this argument, citing People v. Gecomo, which held that a judge who did not hear a case may write the decision based on the records. The Court affirmed that Judge Sanchez’s evaluation of the evidence was sound and supported by the records.

The Court found Condino’s claim of self-defense implausible. The trial court noted that Condino was already safe when he left the basketball game. Waiting for the victim and then launching a surprise attack was inconsistent with self-defense. The nature of the wounds sustained by the victim further undermined Condino’s claim, indicating that Magadia was helpless when attacked. The medical testimony of Dr. Cecilio Macaraeg confirmed that the wounds were inflicted in a manner inconsistent with a struggle, thereby negating Condino’s self-defense argument.

Despite affirming the conviction, the Supreme Court recognized the mitigating circumstance of voluntary surrender. Evidence showed that Condino reported the incident to the police immediately after the killing. Consequently, the Court modified the penalty, imposing an indeterminate sentence ranging from seventeen (17) years and four (4) months to twenty (20) years of reclusion temporal.

FAQs

What was the key issue in this case?	The key issue was whether Alberto Condino’s alleged insanity at the time of the killing could exempt him from criminal liability for the murder of Alejandro Magadia. The court also considered whether Condino acted in self-defense.
What did the court rule about the insanity defense?	The court ruled that for the insanity defense to apply, the accused must prove a complete deprivation of intelligence at the precise moment the crime was committed. Evidence of prior or subsequent mental illness is insufficient without establishing insanity during the act itself.
What evidence did the defense present to support the insanity claim?	The defense presented evidence that Condino was confined at the National Center for Mental Health and diagnosed with psychosis after the incident. However, they failed to provide evidence of his mental state immediately before or during the commission of the crime.
What role did the eyewitness testimonies play in the court’s decision?	The testimonies of Felipe Mojica and Marcelino Cabutihan were crucial in establishing that Condino attacked and killed Magadia. Their accounts, despite minor inconsistencies, provided a clear picture of Condino’s actions.
Why was the claim of self-defense rejected?	The claim of self-defense was rejected because Condino’s actions of waiting for and attacking Magadia were inconsistent with defending himself. The medical evidence and eyewitness accounts indicated that Magadia was helpless when attacked.
What is the significance of the mitigating circumstance of voluntary surrender?	The court recognized that Condino voluntarily surrendered to the police after the incident, which is a mitigating circumstance. This recognition led to a modification of the penalty imposed by the trial court, resulting in a reduced sentence.
How did the court address inconsistencies in the eyewitness testimonies?	The court dismissed the inconsistencies as minor details that did not affect the substance or credibility of the witnesses’ accounts. The key elements of their testimonies aligned, supporting the conclusion that Condino committed the crime.
What was the final ruling in the case?	The Supreme Court affirmed Condino’s conviction for murder but modified the penalty to an indeterminate sentence of seventeen (17) years and four (4) months to twenty (20) years of reclusion temporal, taking into account the mitigating circumstance of voluntary surrender.

In conclusion, the Condino case reinforces the stringent standards for establishing an insanity defense and highlights the necessity of proving the accused’s mental state at the time of the crime. While mental illness is a serious consideration, it does not automatically absolve an individual of criminal responsibility. The ruling serves as a crucial reminder of the evidentiary burden placed on the defense to demonstrate a complete deprivation of reason during the commission of the act.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, VS. ALBERTO CONDINO Y PEREZ, G.R. No. 130945, November 19, 2001