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PEOPLE v. RIO TIBON Y DEISO

FACTS:

The case involves the appeal of Honorio Tibon, who was found guilty of two counts of parricide by the Regional Trial Court (RTC) and affirmed by the Court of Appeals (CA). Tibon was charged with murdering his two children, Keen Gist Tibon and Reguel Albert Tibon, on December 12, 1998, in Manila, Philippines.

During his arraignment, Tibon pleaded not guilty. The prosecution presented several witnesses, including Tibon's common-law wife, Gina Sumingit. She testified that Tibon had a violent outburst after discovering her alleged affair.

On the day of the incident, Tibon's mother and siblings discovered the two children with stab wounds. Tibon, in an attempt to take his own life, stabbed himself in the chest and jumped out of the window. Dr. Emmanuel Aranas conducted an examination of the victims' bodies and confirmed that the cause of death was the stab wounds.

SPO3 Bagkus, a police investigator, interviewed Tibon at the hospital. During the interview, Tibon allegedly confessed to stabbing his children. However, Tibon denied the charges and claimed insanity as a defense.

Based on the evidence presented, the RTC found Tibon guilty and sentenced him to death. On appeal, the CA affirmed the conviction but reduced the penalty to reclusion perpetua.

ISSUES:

  1. Whether the Court of Appeals erred in not considering the exempting circumstance of insanity in favor of the accused-appellant.

  2. Whether the defense of insanity has been met by the accused

  3. Whether the prosecution sufficiently established evidence that the accused voluntarily killed his two children

  4. Whether the penalty imposed is in accordance with the law

  5. Whether the damages awarded are appropriate

RULING:

  1. The Supreme Court affirmed the conviction of the accused-appellant and concluded that the Court of Appeals did not err in not considering the exempting circumstance of insanity in favor of the accused.

  2. The requirements for a finding of insanity have not been met by the defense. The presumption of sanity has not been overcome.

  3. The prosecution sufficiently established evidence that the accused voluntarily killed his two children.

  4. The appellate court correctly modified the sentence of the accused to reclusion perpetua in view of Republic Act No. 9346.

  5. The court awards the following damages to the heirs of the victims: (a) civil indemnity of PhP 75,000 for each victim, (b) actual damages of PhP 173,000, (c) moral damages of PhP 75,000 for each victim, and (d) exemplary damages of PhP 30,000 for each victim.

PRINCIPLES:

  • Insanity is the exception rather than the rule in the human condition.

  • An accused invoking insanity must prove it with clear and convincing evidence.

  • The testimony or proof of an accused's insanity must relate to the time immediately preceding or coetaneous with the commission of the offense.

  • Uncontrolled jealousy and anger are not equivalent to insanity.

  • Only when there is a complete deprivation of intelligence at the time of the commission of the crime should the exempting circumstance of insanity be considered.

  • The commission of parricide is punished more severely than homicide since human beings are expected to love and support those who are closest to them.

  • Civil indemnity is automatically granted to the offended party without need of further evidence other than the fact of the commission of murder, homicide, parricide, and rape.

  • Actual damages must be proved with competent proof or best evidence obtainable, such as receipts.

  • The loss of a loved one to a violent death brings emotional pain and anguish, warranting the award of moral damages.

  • Exemplary damages may be awarded in parricide cases where qualifying circumstances, such as relationship, are alleged and proved.