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People vs.

Alcalde
G.R. Nos. 139225-28
May 29, 2002

FACTS

ARNEL ALCALDE was convicted of two counts of parricide


committed against his wife and his 11-month-old son and two counts of
frustrated parricide committed against his two daughters.

In the arraignment, Alcalde refused to speak, appeared


motionless, and with a single direction blank stare. The trial court
entered for him a plea of not guilty in each of the cases. The defense
waived pre-trial. The cases were then consolidated and jointly tried.
When the prosecution rested its case, Atty. Vasquez filed a
demurrer to evidence based on the grounds that accused was not
adequately informed of the nature and cause of the accusation
because of Alcaldes out of touch of the world behavior during the
arraignment and insufficiency of prosecutions evidence. Thus, there
was a presumption of innocence of the accused.
ISSUE
Whether or not Alcalde had been adequately informed of the
nature and cause of accusation against him during the arraignment.
DECISION
The Supreme Court ruled in the negative. The joint decision was
set aside and remanded the cases to the trial court for further
proceedings to allow the defense to present evidence to prove that
Alcalde was either unfit for trial or was insane at the time the crimes
were committed.
The constitutional right to be informed of the nature and cause of
the accusation against him under the Bill of Rights carries with it the
correlative obligation to effectively convey to the accused the
information to enable him to effectively prepare for his defense.

Supreme Court mentioned the defense counsels lackadaisical


attitude in these cases which amounted to disregard of the strict
demands of fidelity to his oath as a lawyer, duty to his client, and
responsibility as an officer of the court.
He ought from the very beginning that Alcalde was hospitalized
for mental disorder. The latters strange appearance at his arraignment
was enough reason for a counsel to ask for the deferment of
arraignment and for leave of court to have Alcalde subjected to
psychological examination and psychiatric evaluation.
He should have, at the very least, presented the doctor who
treated ARNEL in the University of Santo Tomas Hospital for his
recurring mental illness. Irrefutably, Atty. Vasquezs behavior in the
defense of ARNEL fell short of the demanding duty to present every
defense that the law permits to the end that no person may be
deprived of life or liberty but by due process of law.

KATHRYN A. LIM
LLB-1
JRMSU