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THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LAROY BUENAFLOR y TUAZON Alias "LARRY," Defendant-Appellant

Laroy Buenaflor was convicted of raping Isabella Federis. He claimed mental impairment as a defense. While a medical report found Buenaflor suffered from mental retardation and depression, it did not find complete deprivation of intelligence or freedom of will. Therefore, Buenaflor was not exempt from criminal liability. However, the court acknowledged Buenaflor's mental faculties were somewhat impaired, which was a mitigating circumstance. Nonetheless, the mitigating circumstance did not reduce the penalty of reclusion perpetua, which is an indivisible penalty under the law.

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Kimberly Maralit
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220 views3 pages

THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LAROY BUENAFLOR y TUAZON Alias "LARRY," Defendant-Appellant

Laroy Buenaflor was convicted of raping Isabella Federis. He claimed mental impairment as a defense. While a medical report found Buenaflor suffered from mental retardation and depression, it did not find complete deprivation of intelligence or freedom of will. Therefore, Buenaflor was not exempt from criminal liability. However, the court acknowledged Buenaflor's mental faculties were somewhat impaired, which was a mitigating circumstance. Nonetheless, the mitigating circumstance did not reduce the penalty of reclusion perpetua, which is an indivisible penalty under the law.

Uploaded by

Kimberly Maralit
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs.

LAROY
BUENAFLOR y TUAZON alias “LARRY,” defendant-appellant.

G.R. No. 93752, 15 July 1992

FACTS:

On August 19, 1989, Isabella Federis while walking on her way home
was approached by Laroy Buenaflor who was armed with a knife and
subsequently poked the knife on her neck. He dragged her to a dark
portion of the street and sexually abused her. She tricked him to get
away. On cross-examination, Buenaflor admitted that he poked a
knife at the Isabella Federis and led her to a dark alley where they
had sex with Federis’ consent.

The counsel for appellant stated that his client was suffering from
mental disease. Thus, he was examined by Dr. Imelda Escuadra, a
medical specialist at the Don Susano Rodriguez Regional Mental
Hospital. Her report bears that Buenaflor is suffering from Mental
Retardation and Reactive Depression. However, he is not
psychotic.The trial court convicted Buenaflor guilty beyond
reasonable doubt of the crime of rape.

ISSUE:

Whether Buenaflor was imbecile therefore exempt from criminal


liability.

RULING:
No. Imbecility, like insanity, is a defense which pertains to the mental
condition of a person. Our case law projects the same standards in
respect of both insanity and imbecility, that is, that the insanity or
imbecility must constitute complete deprivation of intelligence in
committing the criminal act, or total deprivation of freedom of the will.

The above quoted medical evidence that was admitted into the record
in the case at bar does not show complete deprivation (nor even
substantial deprivation) of intelligence on the part of appellant
Buenaflor and he, accordingly, cannot be deemed exempted from
criminal liability for the rape of Isabella Federis. His behavior on the
night he raped Isabella showed that he was quite conscious of his
acts and aware of the moral quality thereof.

At the same time, the Court believe, however, that the medical
evidence of record does show that appellant Buenaflor's mental
faculties were to some extent retarded or impaired in their
development, which impairment or retardation reflects a diminished
level of responsibility for his criminal acts. Thus, a mitigating
circumstance contemplated in Article 13 (9) of the Revised Penal
Code was present in the case at bar.

At any rate, the appreciation of a mitigating circumstance in favor of


appellant Buenaflor would not have the effect of reducing the penalty
of reclusion perpetua imposed upon him by the trial court. Article 63
of the Revised Penal Code prescribes that "in all cases in which the
law prescribes a single indivisible penalty, [such penalty) shall be
applied by the courts regardless of any mitigating circumstances that
may have attended the commission of the deed." Reclusion
perpetua is a single indivisible penalty.

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