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?
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.
- Testimony of a Child Witness – Testimonies of young children are given significant weight in cases of domestic violence, especially when the child directly witnessed the crime. Courts generally assume that children do not fabricate stories that could implicate close family members like a parent, lending credibility to their statements.
- Homicide vs. Murder – For a crime to qualify as murder under Article 248 of the Revised Penal Code, it must be attended by specific qualifying circumstances, such as treachery, evident premeditation, or abuse of superior strength. In the absence of these circumstances, the crime is considered homicide under Article 249, which carries a lighter penalty
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Read the full text here
🎓 In this educational
jurisprudential content, 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
📘 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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