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PEOPLE v. RUBEN CABARRUBIAS

FACTS:

Ruben Cabarrubias alias "Amben" and Zosimo Antiporda alias "Samong" were convicted by the Regional Trial Court for the murder of Jonalyn Espiritu in Criminal Case No. 442 and Pedro Espiritu in Criminal Case No. 443. They were sentenced to reclusion perpetua and ordered to indemnify the families of the victims. The information in Criminal Case No. 442 stated that on July 13, 1986, at about 7:00 o'clock at night in Barangay Patoc, Bucay, Abra, Cabarrubias assaulted and stabbed Jonalyn Espiritu, causing her death. The information in Criminal Case No. 443 stated that on the same date, time, and place, Antiporda assaulted and stabbed Pedro Espiritu, causing his death. Cabarrubias pleaded guilty to the lesser offense of homicide in Criminal Case No. 442 but the trial court did not accept his plea. Both defendants pleaded not guilty at their arraignments. The incidents of the cases occurred at around the same time. Talledo Espiritu, the father of Pedro, found his son with a neck wound, who identified Antiporda as the assailant before collapsing and dying. At the same time, Jonalyn, the granddaughter of Domingo Espiritu, was found stabbed and accused Cabarrubias as the assailant. Jonalyn died the next day. Cabarrubias admitted to killing both Jonalyn and Pedro but claimed self-defense and that he was in a state of mind bordering on insanity. However, insanity was not raised as a defense in the trial court, and there was no evidence presented to support such a defense.

ISSUES:

  1. Whether or not Cabarrubias should have been exempted from liability on the ground of insanity and acting under the compulsion of an irresistible force.

RULING:

  1. The defense of insanity was not invoked by Cabarrubias during the trial court proceedings, and no evidence was presented to overcome the presumption of sanity. It is therefore too late to raise the defense of insanity on appeal. Furthermore, the evidence on record does not show any outward act of Cabarrubias to support the defense of acting under the compulsion of an irresistible force.

PRINCIPLES:

  • It is too late to raise the defense of insanity on appeal if it was not invoked during the trial court proceedings.

  • The defense of acting under the compulsion of an irresistible force requires evidence of an outward act to support it.