FACTS:

Accused-appellant Roger Racal @ Rambo is appealing the decision of the Court of Appeals (CA) affirming the Regional Trial Court's (RTC) judgment finding him guilty of murder for stabbing and killing the victim, Jose "Joe" Francisco. The prosecution was able to establish that Racal was the one who stabbed Francisco, resulting in his death. The attack was deliberate and without warning, done swiftly and unexpectedly, affording the victim no chance to resist or escape. The trial court ruled that Racal's defense of insanity was insufficient and convicted him of murder. The CA affirmed his conviction and modified the judgment by imposing interest on the damages awarded to the victim's heirs. The defense of insanity and the claim of self-defense were rejected by both the trial court and the CA. They held that even a frontal attack can be considered treacherous if it is unexpected and the victim is unarmed and unable to defend themselves. The courts referred to a previous case, People v. Estrada, which stated that a person is criminally liable for their actions as our criminal law is primarily based on the concept of human free will. Thus, Racal's conviction for murder was upheld.

ISSUES:

1. Whether the crime committed by the appellant is qualified murder by reason of treachery.

2. Whether the defense of insanity is applicable in this case.

3. Whether the appellant acted without the least discernment or was suffering from a complete absence of intelligence or the power to discern at the time of the commission of the crime.

4. Whether the aggravating circumstance of evident premeditation should be appreciated.

5. Whether the mitigating circumstances of sufficient provocation on the part of the offended party and voluntary plea of guilt should be appreciated.

6. Whether the provocation occurred immediately before the stabbing incident.

7. Whether the voluntary plea of guilt is a mitigating circumstance.

8. Whether the illness of the appellant is a mitigating circumstance.

RULING:

1. The crime committed by the appellant is qualified murder by reason of treachery. The Court held that the sudden and unexpected attack on the victim, coupled with the fact that the victim was unarmed and had no chance to evade the attack, evidenced treachery. Even though the appellant was facing the victim when he stabbed him, a frontal attack can still be considered treacherous when unexpected and done on an unarmed victim who cannot repel or avoid the attack.

2. The defense of insanity is not applicable in this case. The Court stated that the defense failed to overcome the presumption of sanity. The psychiatric evaluations done on the appellant were taken three and four years after the crime was committed, which was not within the period immediately before or at the moment of the commission of the crime. The defense's expert witnesses also failed to support the appellant's claim of insanity. Moreover, the appellant's acts of caring for his sister's children and being their guardian were inconsistent with an insane mind.

3. The defense failed to prove that the appellant acted without the least discernment or that he was suffering from a complete absence of intelligence or the power to discern at the time of the commission of the crime.

4. The aggravating circumstance of evident premeditation should not be appreciated as there is no proof that appellant had previously planned the killing of the victim.

5. The mitigating circumstances of sufficient provocation on the part of the offended party and voluntary plea of guilt should not be appreciated. The teasing and taunting by the victim does not constitute sufficient provocation, and the mitigating circumstance of voluntary plea of guilt was not proven.

6. The provocation did not occur immediately before the stabbing incident as it happened days before. Therefore, the immediacy required by law was absent.

7. The voluntary plea of guilt after arraignment and trial does not entitle the accused to have such plea considered as a mitigating circumstance.

8. The illness of the appellant is a mitigating circumstance as it diminished his capacity to discern what was wrong or right at the time of the commission of the crime.

PRINCIPLES:

• Treachery can be present even in a frontal attack when unexpected and on an unarmed victim who cannot repel or avoid the attack.

• Insanity can be a defense to criminal liability, but the accused must prove it by clear and positive evidence. The evidence must relate to the time preceding the act under prosecution or to the very moment of its execution.

• Inquiries into the mental state of an accused should relate to the period immediately before or at the very moment the felony is committed.

• Circumstantial evidence, if clear and convincing, can be used to establish insanity as a defense, as the unfathomable mind can only be known by overt acts.

• Mere abnormality of mental faculties does not exclude imputability. There must be a complete deprivation of intelligence in committing the act for insanity to be exempting.

• To prove evident premeditation as an aggravating circumstance, the prosecution must establish the time when the offender determined to commit the crime, an act manifestly indicating that the culprit has clung to his determination, and a sufficient lapse of time between the determination and execution to allow reflection.

• Sufficient provocation, as a mitigating circumstance, requires that the provocation be sufficient, immediate to the commission of the crime, and originate from the offended party. The provocation must be adequate enough to excite a person to commit the crime and be proportionate in gravity.

• Provocation must occur immediately before the commission of the crime to be considered as a mitigating circumstance.

• A plea of guilt made after arraignment and after trial had begun does not entitle the accused to have such plea considered as a mitigating circumstance.

• Illness may be considered as a mitigating circumstance if it diminishes the exercise of willpower without depriving the accused of consciousness of his acts.