The Supreme Court (SC) has rejected a man’s defense of insanity when he killed the mother and stepfather of his live-in partner whom he also shot several times due to a relationship dispute in 2014.

With its ruling, the SC affirmed with modifications the Court of Appeals’ (CA) 2020 decision that upheld the trial court’s conviction of Arvi G. Villa for double murder and frustrated murder (attempted murder as modified) in 2018.

The SC decision, which was written by Associate Justice Henri Jean Paul B. Inting and made public last Jan. 19, upheld the CA’s findings that Villa’s act of bringing a gun before going to the house of his live-in partner Maridref R. Tolentino meant that he had already determined his plan to kill.

It also affirmed the CA’s ruling that Villa’s act of attempting to commit suicide indicated his awareness of the profundity of the actions he had committed.

Also, the CA – in rejecting Villa’s appeal from the ruling of the regional trial court (RTC) – gave credence to the psychological evaluation that there was no evidence of serious neurotic, psychotic, or organic disorder on his part.

Arvi’s defense of insanity was presented for the first time during his appeal to the CA.

During the trial before the RTC, Maridref testified that she and Arvi had been live-in partners for seven years and resided at the latter’s house in Novaliches, Quezon City. She said she had been physically and verbally abused by Arvi since 2011.

Case record showed that in June 2014, Maridref decided to end her relationship with Arvi, and moved to her parents’ house in Sta. Ana, Manila.

Arvie went to see Maridref in Sta. Ana, and begged her to go back to him.  Maridref refused.  She requested him to bring all her personal belongings from his house in Novaliches. He complied.

On Aug. 1, 2014 Arvi went to Maridref’s house and cried as he again pleaded her to go back with him.  She again refused and said her decision was final.

Arvi went to the comfort room.  Maridreft went to the living room where her mother and step father were.  He again went to the comfort room. He was seen by Maridreft holding a gun.

Arvi poked his gun at the stepfather.  While Maridreft was running away she heard several gunshots. Noticing she also had gunshot wounds, she ran and sought for help.  The barangay officials brought her to the hospital. She had wounds in her chest, armpit, inner arm, thigh and buttocks.

The police recovered the dead bodies of Maridreft’s mother and step father inside the house.  Witnesses testified that Arvi was lying on the floor.  The firearm was also recovered.

In his defense, Arvi testified he could not recall what happened on Aug. 1, 2014.  What he could remember, he told the court, was that he was in Sta. Ana to fetch Maridreft.  He said he lost consciousness and when he woke up, he was already in the hospital.

However, upon hearing Maridreft’s testimony, Arvi – on cross-examination – professed that all of her statements were true and correct.

On Aug. 29, 2018, the RTC convicted Arvi.  He was sentenced to reclusion perpetua or a maximum jail term of 40 years each for the two counts of murder without eligibility for parole, and eight to 14 years for frustrated murder.

Arvie was also ordered to pay burial and wake expenses, loss of earning capacity, and moral and exemplary damages.

On Sept. 30, 2020, the CA affirmed the RTC’s decision as it modified the award of moral and exemplary damages in the frustrated murder case.  Arvi elevated the case to the SC.

In resolving Arvi’s petition, the SC said:

“In criminal law, the defense of insanity must fall within the purview of moral assumption that every person is presumed to be naturally endowed with faculties of understanding and free will. It is the consent of the will that is primordial to the culpability of one's wrongdoing. Retribution cannot be meted out to those who do not have free will.

“For the courts to appreciate the defense of insanity: ‘first, insanity must be present at the time of the commission of the crime; second, insanity, which is the primary cause of the criminal act, must be medically proven; and third, the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act.’

“In the present case, nothing in the records shows that the accused appellant (Arvi) submitted evidence to prove his insanity during trial, or pleaded this exempting circumstance during his arraignment.

“In fact, the prosecution presented the psychological evaluation of the accused appellant which states that there was no evidence of serious neurotic, psychotic, or organic disorder. Moreover, in People v. Rafanan, Jr. (a previously decided case), the Court held that complete loss of intelligence cannot be acknowledged if the accused is aware of the reprehensible moral quality of his actions.

“Under the circumstances, taking one's own life right after executing his criminal actions is indicative of his awareness of the gravity of his criminal actions contrary to the defense of accused-appellant that his act of suicide is evocative of demented reasoning.

“In the end, insanity cannot be appreciated in his favor and, for that reason, the Court is not persuaded to reverse the conviction of accused appellant.

“Wherefore, the appeal is dismissed. The Decision dated Sept. 30, 2020, of the Court of Appeals in CA-G.R. CR-HC No. 11793 is affirmed with modifications as follows:

“1. In Criminal Case No. 14-307999, accused-appellant Arvi Villa y Garcia is hereby found guilty beyond reasonable doubt of the crime of Murder under Article 248 of the Revised Penal Code, as amended, and is sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole. He is ordered to pay the heirs of Sergio Aguilar, Jr. y Tiamzon the amounts of Pl72,663 for burial and wake expenses, Pl00,000 as civil indemnity, Pl00,000 as moral damages, Pl00,000 as exemplary damages, and P200,000 as temperate damages. All monetary awards are subject to an interest rate of six percent (6%) per annum from the date of finality of this Decision until fully paid.

“2. In Criminal Case No. 14-308000, accused-appellant Arvi Villa y Garcia is hereby found guilty beyond reasonable doubt of the crime of Murder under Article 248 of the Revised Penal Code, as amended, and is sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole. He is ordered to pay the heirs of Maria Lourdes Aguilar y Tolentino the amounts of Pl72,663 for burial and wake expenses, Pl00,000 as civil indemnity, Pl00,000 as moral damages, Pl00,000 as exemplary damages, and P200,000 as temperate damages. All monetary awards are subject to an interest rate of six percent (6%) per annum from the date of finality of this Decision until fully paid.

“3. In Criminal Case No. 14-308001, accused-appellant Arvi Villa y Garcia is hereby found guilty beyond reasonable doubt of the crime of Attempted Murder under Article 248 in relation to Article 51 of the Revised Penal Code, as amended, and is sentenced to suffer the penalty of four (4) years, two (2) months, and one (1) day of prision correccional, as minimum, to ten (10) years and one (1) day of prision mayor, as maximum. He is ordered to pay Maridref Tolentino y Rico the amounts of P160,222 for her medical and attorney's fees, P50,000 as civil indemnity, P50,000 as moral damages, and P50,000 as exemplary damages. All monetary awards are subject to an interest rate of six percent (6%) per annum from the date of finality of this Decision until fully paid. So ordered.”