People v. Calines

Summary

The Supreme Court upheld the conviction of Fernan Calines for murder and attempted homicide. Calines attacked Nida Sabado and her 3-year-old son Sky with a wooden stick in December 2016. Sky died from severe head injuries while Nida sustained non-fatal wounds. The Court rejected Calines's insanity defense, applying a three-way test requiring proof of insanity at the time of commission, medical proof, and inability to appreciate wrongfulness. The psychiatric evaluation conducted two years later was deemed insufficient, and Calines's flight behavior showed consciousness of guilt. The killing of the child was qualified by treachery due to the victim's tender age and inherent defenselessness. The Court affirmed the penalty of reclusion perpetua for murder and imprisonment for attempted homicide, along with corresponding civil damages to the victims' families.