327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a defendant be exonerated by claiming insanity when
substantial evidence points to his guilt for a crime, such as murder, based on
testimonies from key witnesses, including his own child?
Case Title:
People of the Philippines vs. Leonardo Macalindong y
Andallon
G.R. No. 248202 | October 13, 2021
Facts of the Case:
Leonardo Macalindong was charged with the murder of his
live-in partner, Jovelia Malinao, on February 10, 2007. According to the
testimony of their seven-year-old daughter, Lyn Joy, she witnessed her father
stab her mother multiple times while her brother was asleep. The crime took
place in their home in Victoria, Oriental Mindoro. The police arrested Leonardo
after Lyn Joy identified him as the perpetrator.
The defense argued that Leonardo had no recollection of the
crime due to schizophrenia, presenting medical certificates to support his
claim. He asserted that he blacked out and could not remember the events
leading to Jovelia's death. However, the trial court gave greater credence to
the prosecution’s evidence, particularly the testimony of Lyn Joy, and
convicted Leonardo of murder. The Regional Trial Court of Calapan City
sentenced him to reclusion perpetua.
Leonardo appealed to the Court of Appeals (CA), contending
that the trial court erred in appreciating the qualifying circumstances of
treachery and ignoring his insanity plea. The CA affirmed the trial court's
decision but modified it by appreciating the qualifying circumstance of abuse
of superior strength in addition to treachery. Leonardo then appealed to the
Supreme Court.
Issue:
Can the appellant be credited with the exempting
circumstance of insanity? And was the appellant properly convicted of murder?
Supreme Court Ruling:
The Supreme Court ruled that the defense of insanity was not
substantiated with sufficient evidence. While Leonardo submitted medical
certificates indicating schizophrenia, no expert testimony was presented to
prove that he was insane at the time of the crime. Merely claiming to have
blacked out is not sufficient to establish insanity. The law requires evidence
that insanity existed at the time of or immediately preceding the commission of
the crime. The appellant’s inability to remember does not exculpate him from
liability.
However, the Court found that the killing was not attended
by treachery or abuse of superior strength. The attack, although sudden,
occurred during a quarrel, indicating an impulsive rather than premeditated or
treacherous act. As a result, the Court downgraded the crime from murder to
homicide and sentenced Leonardo to a lesser penalty.
Dispositive Portion:
The Supreme Court modified the ruling of the Court of
Appeals. Leonardo Macalindong was found guilty of homicide and sentenced to
imprisonment of eight (8) years and one (1) day of prision mayor as the
minimum, to fourteen (14) years and eight (8) months of reclusion temporal
as the maximum. Additionally, Leonardo was ordered to pay P50,000 as civil
indemnity, P50,000 as moral damages, and P50,000 as temperate damages to the
heirs of Jovelia Malinao. All monetary awards shall earn six percent (6%) legal
interest per annum from the finality of the decision until fully paid.
Should a person suffering from mental illness be held fully
accountable for their actions, even when they claim to have no recollection of
the crime?
Important Doctrines:
- Insanity
Defense Standard – The plea of insanity must be proven by clear
evidence showing that the accused had a complete deprivation of
intelligence and reason at the time of the crime. Mere claims of blackouts
or mental illness without substantial proof do not exempt one from criminal
liability.
- Treachery
and Abuse of Superior Strength – For treachery or abuse of superior
strength to qualify a killing as murder, there must be deliberate intent
and premeditation in the manner of the attack. An impulsive or
heat-of-the-moment act does not automatically qualify as treachery.
- Presumption
of Sound Mind – The law presumes every person to be of sound mind. The
burden of proof lies on the defendant to establish insanity beyond a
reasonable doubt.
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🎓 INTRODUCTION TO
SUPREME COURT JURISPRUDENCE: People v. Leonardo Macalindong y Andallon
📚 For Law Students and
Future Bar Takers
In this educational jurisprudential video, we will discuss key
criminal law doctrines taken from the Supreme Court’s decision in People
of the Philippines vs. Leonardo Macalindong y Andallon, G.R. No. 248202,
promulgated on October 13, 2021.
This video aims to help law students and bar examinees
recall and internalize fundamental doctrines on criminal liability, the
insanity defense, and the classification between homicide and murder.
🔎 CASE OVERVIEW
- Title:
People of the Philippines vs. Leonardo Macalindong y Andallon
- Nature:
Criminal Law – Homicide (initially charged as murder)
- Promulgation
Date: October 13, 2021
- Parties:
The State (Plaintiff-Appellee) vs. Leonardo Macalindong
(Accused-Appellant)
- G.R.
No.: 248202
Brief Summary:
Leonardo Macalindong was charged with murder for
stabbing his live-in partner 22 times. He invoked insanity as a defense.
The trial and appellate courts convicted him of murder, citing treachery
and abuse of superior strength. The Supreme Court, however, downgraded the
conviction to homicide, ruling that no qualifying circumstances were
sufficiently proven and that the insanity defense lacked substantiation.
🤔 Should courts accept
the claim of mental illness if no expert takes the stand to confirm the
accused's condition during the time of the crime?
📌 10 IMPORTANT
DOCTRINES FROM THE DECISION (FOR BAR & LAW SCHOOL RECALL)
(Source: G.R. No. 248202, October 13, 2021)
- Insanity
must be proven by clear, positive evidence.
Mere claims of blackouts or schizophrenia are insufficient; expert testimony must establish that the accused was insane at the time of the crime.
📖 [Macalindong, p. 23] - Treachery
requires conscious adoption of a method of attack.
A sudden attack during a quarrel, without premeditated planning to ensure no retaliation, negates treachery.
📖 [Macalindong, p. 32] - Abuse
of superior strength must be purposeful.
It must be shown that the accused consciously sought advantage due to physical strength or weapon.
📖 [Macalindong, p. 33] - Blackout
is not insanity.
A mere lapse in memory is not legal insanity; the burden is on the defense to prove otherwise.
📖 [Macalindong, p. 23–24] - Child
witness testimony can be credible and sufficient for conviction.
The candid, detailed testimony of a 7-year-old daughter was considered positive and credible evidence.
📖 [Macalindong, p. 26] - Intent
to kill can be inferred from number and location of wounds.
Stabbing a victim 22 times demonstrates intent to kill beyond reasonable doubt.
📖 [Macalindong, p. 35] - Absence
of qualifying circumstances downgrades murder to homicide.
Without treachery or abuse of strength, the crime committed is only homicide.
📖 [Macalindong, p. 34] - Legal
interest on damages starts from finality of judgment.
In unliquidated damages, 6% interest runs only from the finality of the decision.
📖 [Macalindong, citing Nacar v. Gallery Frames, p. 38] - Denial
is a weak defense against positive identification.
An uncorroborated denial cannot overcome a categorical identification by a witness.
📖 [Macalindong, p. 27] - Even
schizophrenia does not guarantee exemption from criminal liability.
If the accused fails to prove total deprivation of reason, the claim of insanity fails.
📖 [Macalindong, p. 23–24]
⚖️ DISCLAIMER:
This video is for educational purposes only and aims
to assist law students and bar reviewees in understanding Philippine
jurisprudence. While we strive for accuracy, we do not guarantee that the
content is infallible. This material was made using premium AI tools
and does not substitute professional legal advice.
❓ FREQUENTLY ASKED QUESTIONS
(FAQs):
- Can
insanity be proven with just medical certificates?
➡️ No. The Supreme Court requires expert testimony to prove that insanity existed at the time of the crime. - Why
was the crime downgraded from murder to homicide?
➡️ Because the Court ruled that neither treachery nor abuse of superior strength was sufficiently proven. - Is
a child witness considered reliable in court?
➡️ Yes, especially if the testimony is consistent, detailed, and based on firsthand knowledge. - Does
schizophrenia automatically exempt someone from criminal liability?
➡️ No. The accused must prove that it caused total deprivation of reason during the act. - Can
an attack during a fight be considered treachery?
➡️ Not necessarily. The attack must be premeditated and ensure no risk to the offender.
📲 Like, Share, and
Comment your thoughts below!
What do you think about using insanity as a defense
in violent crimes?
#PHLaw #BarReview #CriminalLaw #InsanityDefense
#SupremeCourt #HomicideVsMurder #LegalDoctrine #CaseDigest #LawStudentContent
#PhilippineLaw
From <https://chatgpt.com/c/66eebab9-e260-800a-bc2f-c1a900132610>
🎓 INTRODUCTION TO
QUIZZER: Supreme Court Case on Criminal Law
📘
Test Your Knowledge: People v. Leonardo Macalindong y Andallon
Welcome to this interactive Criminal Law quizzer designed
for law students, bar examinees, and legal enthusiasts! This quiz focuses on a
notable Supreme Court decision:
Title: People of the Philippines vs. Leonardo
Macalindong y Andallon
G.R. No.: 248202
Promulgation Date: October 13, 2021
Nature of Case: Criminal Law – Homicide (originally charged as
murder)
Parties: The People of the Philippines (Plaintiff-Appellee) vs. Leonardo
Macalindong (Accused-Appellant)
Brief Case Summary:
This case involves the tragic death of Jovelia Malinao, who was stabbed 22
times by her live-in partner, Leonardo Macalindong. Charged with murder,
Macalindong pleaded insanity, citing schizophrenia. His daughter, only seven
years old, testified that she witnessed the act. The lower courts found him
guilty of murder based on the presence of qualifying circumstances. However,
the Supreme Court reversed the finding, ruling that neither treachery nor abuse
of superior strength was proven beyond reasonable doubt. As a result, the
conviction was downgraded to homicide, and the appellant was sentenced
accordingly.
💡 At the end of this
video, you will find the Answer Key to check how well you understood the
doctrines from the case.
🧠 10 EASY DIFFICULTY
HOTS (Higher-Order Thinking Skills) MULTIPLE CHOICE QUESTIONS
- What
ultimately caused the Supreme Court to reduce the crime from murder to
homicide?
A. The accused was proven insane
B. Lack of clear proof of qualifying circumstances
C. The victim survived the stabbing
D. The accused pleaded guilty - Which
defense did the accused primarily rely on to avoid criminal liability?
A. Accident
B. Self-defense
C. Insanity
D. Mistaken identity - Who
gave the key eyewitness testimony that identified the accused as the
assailant?
A. A barangay official
B. The accused's employer
C. The victim’s neighbor
D. The accused’s minor daughter - Why
did the Supreme Court reject the claim of insanity?
A. The accused denied killing the victim
B. There was no proof of medical treatment
C. No expert testified about the accused’s mental state during the crime
D. The accused appeared calm in court - What
was the daughter doing when she witnessed the crime?
A. Playing outside
B. Sleeping
C. In the same room as her parents
D. Watching TV - How
many times did the victim sustain stab wounds, as stated in the testimony?
A. Five
B. Eleven
C. Twenty-two
D. Thirty - Why
was the qualifying circumstance of abuse of superior strength not
appreciated?
A. The victim was armed
B. The attack was not premeditated
C. The accused was weaker than the victim
D. There were multiple attackers - What
was the primary reason treachery was not appreciated in the ruling?
A. The victim was warned
B. The accused fled the scene
C. The attack was impulsive and not deliberately planned
D. The weapon used was not lethal - Which
of the following best describes the Supreme Court’s view on uncorroborated
denial by an accused?
A. Strong if consistent
B. Acceptable if not rebutted
C. Weak compared to a positive identification
D. More reliable than circumstantial evidence - When
does legal interest on unliquidated damages start to run, according to the
Court?
A. From the date of crime
B. From the filing of the information
C. From the decision of the trial court
D. From the finality of judgment
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