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People vs Yam-id June 21, 1999 Accused-Appellant: Erlindo Yam -id alias Ely
Automatic Review of a decision of the RTC of Toledo City FACTS: On April 1, 1994, at around 2 o’clock in the afternoon, Julius Cantutay was with his 6 -year-old cousin Jerry to deliver benignit, a local delicacy, to his aunt Bebing Dequiado. On their way, they passed by Yam-id’s Yam- id’s house who greeted them “good evening.”
Yam-id suddenly unsheated a long bolo. Julius pushed Jerry and told him to run but Yam-id caught up with Jerry and stabbed him with the bolo on the left portion of his back, held him by his head and hacked him on the nape and stabbed him on the right side of his back. Jerry died on the spot and Yam-id knelt over the body and sucked the blood from his neck. Julius ran towards the house of Danilo Tejamo, Jerry’s father, and narrated the harrowing incident to Aniceta Tejamo, Jerry’s mother. They both ran to the site of the incident and Danilo asked Yam-id the whereabouts of his son. Yam-id Yam-id instead answered “I will kill all of you” and hacked Danilo. Danilo was able to doge the attack but he slipped and fell to the ground. He got hit on the bridge of his nose. He tried to stand but he was hit on the head and fell on the ground again, bloodied. Aniceta shouted that Danilo was already dead. Yamid took hold of Danilo’s collar to finish him off but the tip of the bolo hit his stomach and blood oozed from the wound. Yam-id ran towards his house and threw the bolo on the ground. Danilo regained consciousness and sought treatment. During trial, he denied killing Jerry and pleaded self-defense for his assault on Danilo. He contended that Danilo fired at his house because of a land dispute between his family and the inlaws of Danilo. Judgment of Trial Court: guily of murder and sentenced with death penalty for killing Jerry; guilty of frustrated homicide and imprisonment of 6 yrs and 1 day of prision mayor in its minimum to 10 yrs of prision mayor in its maximum period. In this automatic review, Yam-id admits killing Jerry and pleaded insanity and seeks reversal on his attack on Danilo on the ground that prosecution failed to prove his intent to kill. ISSUE/HELD/RATIO:
WON the appellant can invoke insanity as an exempting circumstance in this case -- NO For insanity to be appreciated as an exempting circumstance, it must be present immediately before or at the very moment the crime was committed. In this case, no evidence was presented to prove the same. The defense of insanity was not raised during the trial of the case. It was only invoke on appeal, giving the court the impression that is but an afterthought. The only intimation of insanity could at is the non-medical opinion of the PAO that he was suffering from schizophrenia because he sipped his victim’s blood and tried to kill himself afterwards. No medical certificate was presented and no testimony was given to support the allegation. There is also treachery when an adult person illegally attacks a child of tender years without any means to defend himself.
On the assault on Danilo, it was reduced to attempted homicide because the wounds were not life threatening. Judgment modified: Guilty of murder -- reduced penalty of reclusion perpetua (no aggravating nor mitigating circumstance) and guilty of attempted homicide – 2 mos and 1 day of arresto mayor as minimum to 2 yrs, 4 mos, and 1 day of prision correctional as maximum.