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 he’ll 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 latter’s 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.

RULING:
(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.