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People vs. Rafanan, JR.

1) The defendant, Policarpio Rafanan, was accused of raping a 14-year-old house helper, Estelita Ronaya, in 1976 by threatening her with a bolo knife. 2) Rafanan claimed an insanity defense due to schizophrenia but failed to provide clear evidence of his mental state at the time of the assault. 3) The court upheld Rafanan's conviction, finding that his expert witnesses did not characterize his mental state at the important time period surrounding the rape.

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55 views8 pages

People vs. Rafanan, JR.

1) The defendant, Policarpio Rafanan, was accused of raping a 14-year-old house helper, Estelita Ronaya, in 1976 by threatening her with a bolo knife. 2) Rafanan claimed an insanity defense due to schizophrenia but failed to provide clear evidence of his mental state at the time of the assault. 3) The court upheld Rafanan's conviction, finding that his expert witnesses did not characterize his mental state at the important time period surrounding the rape.

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eipangilinan
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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People v.

Rafanan,
Jr.,
G.R. No. 54135, November 21,
1991
Pangilinan, Alfredo Jr Cruz
Facts
 On February 27, 1976, complainant Estelita Ronaya who was then only
fourteen years old was hired as a house helper by the mother of the
accused, Ines Rafanan.
 The accused Policarpio Rafanan and his family lived with his mother in the
same house at Barangay San Nicolas, Villasis, Pangasinan. Policarpio was
then married and had two children.
Facts
 On March 16, 1976, in the evening, he accused called the complainant to help
him close the door of the store and as the latter complied and went near him,
he suddenly pulled the complainant inside the store and insisted to have sex
with the complainant.
 The accused wielded a 1.5 foot bolo, including the handle, which he pointed at
the complainant's throat, threatening her with the bolo if she did not comply.
Then, despite her resistance and effort, he made her to lie down on a bamboo
bed, removed her pants, and after unzipping the zipper of his own pants, went
on top of the complainant and succeeded in gaining sexual knowledge of her.
Facts
 The accused warned the complainant not to tell her mother or anybody else
in the house about the incident because he would kill her if she did. The
complainant notified her mother the next morning, March 18, 1976, that she
had been raped by the accused.
 Appellant entered a not guilty plea at his arraignment. The case was then
brought to trial, and the appellant was found guilty by the trial court.
Issue
 Whether the lower court erred in convicting appellant
who at the time of the alleged rape was suffering from
insanity.
Ruling
 Schizophrenia, as claimed by the appellant, is a chronic
mental condition marked by an inability to discern between
fiction and reality, as well as hallucinations and delusions.
Every man is presumed to be sane by the law. The burden of
proof is on the individual accused of a crime to prove his
positive accusation of insanity.
Ruling
 The appellant failed to show clear and compelling evidence about his
mental state prior to and during the sexual assault on Estelita. It has been
decided that an investigation of the accused's mental state should focus on
the time leading up to or immediately after the act is committed.
Ruling
 Appellant's case was built on the testimony of two (2) physicians (Dr.
Jovellano and Dr. Nerit), who did not purport to characterize his mental
state at that important period. They had nothing to do with the events of the
day of the rape or the days leading up to it. Their testimonies comprised of
broad generalizations based on the basic behavioral characteristics of
schizophrenic patients.

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