People vs. Estrada, G.R. No. 130487.
June 19, 2000 suspended depends on the question of whether the accused, even with the
Topic: Right to Impartial Trial
Summary:
By depriving appellant of a mental examination, the trial court effectively
deprived appellant of a fair trial. The trial court’s negligence was a violation
of the basic requirements of due process; and for this reason, the
proceedings before the said court must be nullified
Facts:
Roberto Estrada was charged with the crime of murder for the killing of one
Rogelio P. Mararac, a security guard. It was alleged that accused could not
properly and intelligently enter a plea because he was suffering from a
mental defect. He prayed for suspension of arraignment. Trial Court decided
that it was answered intelligently. Hence, denying the prayer. Appellant’s
counsel filed a demurer of evidence. He claimed that that prosecution failed
to prove the crime of mirder and that there was unlawful aggression by the
victim, which was denied by the court. Appellant’s counsel presented Dr.
Soledad who testified that Estrada had been confined in the hospital and
suffered from Schizoprenic Psychosis. RTC upheld the prosecution’s
evidence and found Estrada guilty of the crime charged.
Issue:
WON, there was a fair trial.
Held:
No fair trial. By depriving appellant of a mental examination, the trial court
effectively deprived appellant of a fair trial. Case is remanded to the court a
quo for the conduct of a proper mental examination on accused-appellant, a
determination of his competency to stand trial, and for further proceedings.
The question of suspending the arraignment lies within the discretion of the
trial court. And the test to determine whether the proceedings will be
assistance of counsel, would have a fair trial. This rule was laid down as
early as 1917, thus: “In passing on the question of the propriety of
suspending the proceedings against an accused person on the ground of
present insanity, the judges should bear in mind that not every aberration
of the mind or exhibition of mental deficiency is sufficient to justify such
suspension. The test is to be found in the question whether the accused
would have a fair trial, with the assistance which the law secures or gives;
and it is obvious that under a system of procedure like ours where every
accused person has legal counsel, it is not necessary to be so particular as it
used to be in England where the accused had no advocate but himself.”
The fact that accused-appellant was able to answer the questions asked by
the trial court is not conclusive evidence that he was competent enough to
stand trial and assist in his defense. Section 12, Rule 116 speaks of an
unsound mental condition that “effectively renders [the accused] unable to
fully understand the charge against him and to plead intelligently thereto.”
It is not clear whether accused-appellant was of such sound mind as to fully
understand the charge against him. It is also not certain whether his plea
was made intelligently. The plea of “not guilty” was not made by accused-
appellant but by the trial court “because of his refusal to plead.” The trial
court took it solely upon itself to determine the sanity of accused-appellant.
The trial judge is not a psychiatrist or psychologist or some other expert
equipped with the specialized knowledge of determining the state of a
person’s mental health. To determine the accused-appellant’s competency
to stand trial, the court, in the instant case, should have at least ordered the
examination of accused-appellant, especially in the light of the latter’s
history of mental illness.
By depriving appellant of a mental examination, the trial court effectively
deprived appellant of a fair trial. The trial court’s negligence was a violation
of the basic requirements of due process; and for this reason, the
proceedings before the said court must be nullified. In People v. Serafica, we
ordered that the joint decision of the trial court be vacated and the cases
remanded to the court a quo for proper proceeding. The accused, which
was charged with two (2) counts of murder and one (1) count of frustrated
murder, entered a plea of “guilty” to all three charges and was sentenced to
death. We found that the accused’s plea was not an unconditional
admission of guilt because he was “not in full possession of his mental
faculties when he killed the victim”; and thereby ordered that he be
subjected to the necessary medical examination to determine his degree of
insanity at the time of commission of the crime.