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Case Digest on PEOPLE V. ROBERTO ESTRADA G.R. NO. 130487

November 27, 2010


Accused was convicted for murder and sentenced to death.  Defense interposed insanity with proof of his history of mental illness filed for suspension of arraignment and suspension of proceedings.  Both were denied without subjecting accused to mental examination.

HELD:

Case remanded for the conduct of a proper mental examination to determine competency to stand trial.  By depriving appellant of mental examination, the trial court effectively deprived appellant of a fair trial and the proceedings before the court are therefore nullified. He who invokes insanity as an exempting circumstance must prove it by clear and positive evidence.  The absence of direct proof however, does not entirely discount the probability that accused was not of sound mind at that time. In passing the question of the propriety of suspending the proceedings, the test is found in the question whether the accused would have a fair trial with the assistance which the law secures or gives.  There are 2 distinct matters to be determined under this test (1) whether the defendant is sufficiently coherent to provide his counsel with information necessary or relevant to constructing a defense and (2) whether he is able to comprehend the significance of the trial and his relation to it.

The determination of whether a sanity investigation or hearing should be ordered rests generally in the discretion of the trial court.  In the case, the trial court took it solely upon itself to determine the sanity of the accused.  The trial judge however is not a psychiatrist or psychologist or some other expert equipped with the specialized knowledge of determining the state of a person’s mental health.  The court should have at least ordered the examination of the accused, especially in the light of the latter’s history of mental item.

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