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PEOPLE v. RENEGADO
August 3, 2012 Leave a comment
PEOPLE v. RENEGADO
May 31, 1974 (G.R. No. L-27031)
PARTIES:
plaintiff-appellee: THE PEOPLE OF THE PHILIPPINES
accused-appellant: LORETO RENEGADO y SENORA
FACTS:
Mamerto de Lira was a math teacher in Tiburcio Tancinco Memorial Vocational School which is
run by the national government. Loreto Renegado was a clerk in the same school. De Lira asked
Renegado to type his exam questions but the latter refused. They had a small argument which
left the accused fuming with anger. The accused told several people that hell gonna kill the
deceased. They pacified him and told him the possible consequences that may happen. After a
few days, while the deceased was in the canteen sitting with his back towards the accused,
without warning the accused stabbed the deceased with a knife which later caused the latters
death. The counsel of the accused pleads for an acquittal on the ground that the accused
should be exempt from criminal liability because at the precise time he stabbed de Lira, the
accused lost his senses and he simply did not know what he was doing. His counsel claimed that
after Renegado was clubbed on the forehead, he suffered from head injury which produced ill-
effects.

ISSUE:
(1) WON the accused is exempt from criminal liability on the ground of insanity.
(2) What are the mitigating and aggravating circumstances present in the case.

HELD:
(1) No. Insanity exists when there is a complete deprivation of intelligence in committing act,
that is, the accused is deprived of reason, he acts without the least discernment because there
is a complete absence of the power to discern, or that there is a total deprivation of freedom of
the will, mere abnormality of the mental faculties will not exclude imputability. In the case at
bar, it just shows that Renegado is a man of violent temper who can be easily provoked to
violence for no valid reason at all. Thus in People vs. Cruz, this Court held that breaking glasses
and smashing dishes are simply demonstrations of an explosive temper and do not constitute
clear and satisfactory proof of insanity; they are indications of the passionate nature of the
accused.
In the absence of proof that the defendant had lost his reason or became demented a few
moments prior to or during the perpetration of the crime, it is presumed that he was in a
normal condition of mind.
(2) The killing of Mamerto de Lira is qualified by evident premeditation. Here, the accused has
more or less sixty-four hours to ponder over his plan and listen to the advice of his co-
employees and of his own conscience, and such length of time was more than sufficient for him
to reflect on his intended revenge.
There is treachery committed. There is treachery where the victim who was not armed was
never in a position to defend himself or offer resistance, nor to present risk or danger to the
accused when assaulted. The accused killed the deceased while he was eating and his back
faced towards him.
There was an assault upon a person in authority. A teacher either of a public or of a duly
recognized private school is a person in authority.
The mitigating circumstance of voluntary surrender was offset by the aggravating circumstance
of treachery.

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LACSON VS POSADAS 72 SCRA 168 (1976)
Respondent Municipal Judge Ramon Posadas, of Talisay Negros Occidental,
is charged in a verifiedcomplaint by Salvador Lacson, Jr. with (a) ignoranceof the law,
(b) partiality, and (c) violation of theElection Code of 1971 which provides
that:Any person who has been refused registration orwhose name has been stricken out from t
hepermanent list of voters may at any time exceptsixty (60) days before a regular election or
twenty-five (25) days before a special election, apply to
theproper court for an order directing the electionregistration board or the board of inspectors
as thecase may be, to include or reinstate his name in thepermanent list of voters, attaching to
his
applicationfor inclusion the certificate of the Electronregistration board or the board of inspect
orsregarding his case and proof of service of a copy of his application and of the notice of
hearing thereof upon a member of the said board (Emphasissupplied.)In the light of the
statutory purpose, the
seriousnessof respondent's failure to comply with therequirements of Section 136 of the electo
ral lawbecomes evident. His good faith or lack of malice isof no avail, considering that in crimes
which are
mala prohibita
the act alone irrespective of its motives,constitutes the offense. It appears, however, that
onApril 8, 1974, the President of the Philippinespromulgated Presidential Decree No. 433, whic
hgrants general amnesty under certain conditions
topublic school teachers, other government officialsand employees, members of the armed
forces of thePhilippines and other persons for violation of electionlaws and other related
statutes in connection withthe elections of 1965, 1967, 1969, 1971, and
theelection of delegates to the ConstitutionalConvention.WHEREFORE, respondent is hereby
admonished thathe should exercise greater care in the observance of the provisions of existing
laws in the discharge of his judicial duty, and warned that any subsequentmisconduct shall be
dealt with more severely.