Criminal Law

Case Digests — Defense of Insanity

People v. Wilson Cacho  

G.R. No. 218425, September 27, 2017

 

FACTS:

 

PO2 Salen and SPO4 Tavas received a report about a fire in Sitio Catmon, Brgy. San Rafael, Rodriguez, Rizal.

Upon arriving, they saw a burned house, which was owned by a certain Boy who was later identified as Mario Balbao. Upon investigation, they discovered a burned body of a headless man underneath an iron sheet. Willy Cacho informed the police officers that it was his brother, [accused-appellant], who killed Boy. [Accused-appellant’s] wife likewise told the police officers that her husband was a patient of [the] National Center for Mental Health and has a recurring mental illness.

The police officers went to the house of [accused-appellant] and saw him in his backyard. Upon introducing themselves as police officers, [accused-appellant] acted strangely and exhibited signs of mental illness. According to SPO4 Tavas, [accused-appellant] admitted killing Boy and burning the latter’s house but did not say why he did it.

After the inquest, subsequent to his arrest, [accused-appellant] was brought to the National Center for Mental Health for confinement.

After trial, the RTC found accused-appellant guilty of the crimes of Murder and Destructive Arson and was ordered to be committed to the National Bilibid Prisons, Muntinlupa City for service of sentence.

Upon appeal, the CA affirmed the judgment of conviction of the accused-appellant of the crimes charged.

 

ISSUE:

Whether the accused-appellant sufficiently proved his defense of insanity.

 

RULING:

Accused-appellant was not able to sufficiently prove his defense of insanity.

Accused-appellant alleged that he was diagnosed with Major Depression with Psychosis in 1996 for which he was admitted at the National Center for Mental Health (NCMH) for two (2) months. Then on January 7, 2004, he was again admitted to the NCMH and it was discovered that his Major Depression with Psychosis had already progressed to Chronic Schizophrenia.

In the case of People v. Isla, it stated that:

Article 12 of the [RPC] provides for one of the circumstances which will exempt one from criminal liability which is when the perpetrator of the act was an imbecile or insane, unless the latter has acted during a lucid interval. This circumstance, however, is not easily available to an accused as a successful defense.

Insanity is the exception rather than the rule in the human condition. Under Article 800 of the Civil Code, the presumption is that every human is sane. Anyone who pleads the exempting circumstance of insanity bears the burden of proving it with clear and convincing evidence. It is in the nature of confession and avoidance. An accused invoking insanity admits to have committed the crime but claims that he or she is not guilty because of insanity. x x x.

However for the defense of insanity to be successfully invoked as a circumstance to evade criminal liability, it is necessary that insanity must relate to the time immediately preceding or simultaneous with the commission of the offense with which the accused is charged. Otherwise, he can be held guilty for the said offense.

In short, in order for the accused to be exempted from criminal liability under a plea of insanity, he must successfully show that:

(1) he was completely deprived of intelligence; and

(2) such complete deprivation of intelligence must be manifest at the time or immediately before the commission of the offense.

 

Accused-appellant having invoked the defense of insanity, he is deemed to have admitted the commission of the crime. As such, he is bound to establish with certainty that he is completely deprived of intelligence because of his mental condition or illness.

After the careful review of the records of the case, We found that the accused-appellant failed to prove that he is insane immediately prior or at the time of the commission of the crime.

People v. Tibon

G.R. No. 188320 June 29, 2010

 

FACTS:

Accused-appellant and his common-law wife Gina had two children and lived with accused-appellant’s parents and siblings on the third floor of a rented house. Due to financial difficulties, Gina went to Hong Kong to work as a domestic helper. After the revelation that Gina was having an affair with another man, he started drinking a lot and was seen hitting his two children.

On the night of December 12, 1998, accused-appellant’s mother and his siblings, went to accused-appellant’s room and saw him with his two children who appeared lifeless and bore wounds on their bodies. When accused-appellant realized that his mother and siblings had seen his two children lying on the floor, he stabbed himself on the chest with a kitchen knife and tried to end his life by jumping out the window of their house.

Accused-appellant and his two children, were rushed to the hospital where accused-appellant received treatment for his injuries. The two children, however, could no longer be revived.

Tibon confided that he was despondent and voluntarily admitted to stabbing KenKen and Reguel.

Tibon raised insanity as defense.

The RTC found Tibon GUILTY beyond reasonable doubt of the crime of two counts of Parricide.

The CA affirmed the findings of the RTC and found that the defense did not overcome the presumption of sanity.

 

ISSUE:

WHETHER THE COURT OF APPEALS GRAVELY ERRED IN NOT CONSIDERING THE EXEMPTING CIRCUMSTANCE OF INSANITY IN FAVOR OF THE ACCUSED-APPELLANT.

 

RULING:

We affirm Tibon’s conviction.

Parricide is committed when: (1) a person is killed; (2) the deceased is killed by the accused; (3) the deceased is the father, mother, or child, whether legitimate or illegitimate, or a legitimate other ascendant or other descendant, or the legitimate spouse of the accused.

This appeal admits that parricide has indeed been committed. The defense, however, banks on Tibons insanity to exempt him from punishment.

The defense has unsatisfactorily shown that Tibon was insane when he stabbed his two young sons.

Insanity is the exception rather than the rule in the human condition. While Art. 12(1) of the RPC provides that an imbecile or insane person is exempt from criminal liability, unless that person has acted during a lucid interval, the presumption, under Art. 800 of the Civil Code, is that every human is sane. Anyone who pleads the exempting circumstance of insanity bears the burden of proving it with clear and convincing evidence. It is in the nature of confession and avoidance.

An accused invoking insanity admits to have committed the crime but claims that he or she is not guilty because of insanity. The testimony or proof of an accused’s insanity must, however, relate to the time immediately preceding or coetaneous with the commission of the offense with which he is charged.

We reiterate jurisprudence which has established that only when there is a complete deprivation of intelligence at the time of the commission of the crime should the exempting circumstance of insanity be considered.

In People v. Ocfemia, this Court ruled that the professed inability of the accused to recall events before and after the stabbing incident, as in the instant case, does not necessarily indicate an aberrant mind but is more indicative of a concocted excuse to exculpate himself. It is simply too convenient for Tibon to claim that he could not remember anything rather than face the consequences of his terrible deed.

The requirements for a finding of insanity have not been met by the defense. As the appellate court noted, Tibon’s unusual behavior prior to and after he committed parricide do not meet the stringent standards on an insanity plea as required by this Court. The presumption of sanity has not been overcome.

 

People v. Isla

G.R. No. 199875  November 21, 2012

 

FACTS:

Evidence for the Prosecution

According to AAA’s account, on July 21, 1997, at around 3:00 o’clock in the afternoon, she was inside her rented house together with her two children, aged 1 ½ years old and 9 months old. She noticed that accused Edwin Isla standing by the door of her kitchen. After 15 minutes, she was startled when he suddenly poked a knife on her neck and pulled her inside the bedroom. Isla placed himself on top of her and had carnal knowledge with her.

When Isla stood up after raping her, she noticed that the knife he was holding was already bloodstained. At this point, she found out that she was stabbed with the knife.

Isla scampered out of the house through the backdoor.

Evidence for the Defense

Isla never denied that he raped AAA. Invoking the defense of insanity, he testified that before the incident, he and AAA had an illicit relationship for about two months until they broke up. After raping her, he admitted stabbing AAA twice “for reason he cannot understand.”

For the defense, two psychiatric doctors who examined him were presented as witnesses.

Dr. Villacorta testified that Isla was suffering from a major depressive disorder with psychotic features; that he manifested psychosis on account of his hallucinations, poor impulse control, poor judgment, and low frustration tolerance; and that he exhibited such behavioral pattern immediately prior to being jailed.

After a thorough interview and psychiatric testing on Isla, Dr. Gomez likewise observed that Isla was suffering from a major depressive disorder which impaired his mental faculties.

 

The RTC convicted Isla of the crimes of rape and frustrated murder. It did not give credence to his defense of insanity because it noted that Isla committed the crimes charged during a lucid interval.

The CA denied the appeal and affirmed the RTC decision.

 

ISSUE:

Whether or not THE ACCUSED-APPELLANT WAS INSANE AT THE TIME OF THE COMMISSION OF THE OFFENSE.

 

RULING:

This Court is not convinced with Isla’s defense.

Article 12 of the RPC provides for one of the circumstances which will exempt one from criminal liability which is when the perpetrator of the act was an imbecile or insane, unless the latter has acted during a lucid interval. This circumstance, however, is not easily available to an accused as a successful defense. Insanity is the exception rather than the rule in the human condition. Under Article 800 of the Civil Code, the presumption is that every human is sane. Anyone who pleads the exempting circumstance of insanity bears the burden of proving it with clear and convincing evidence. It is in the nature of confession and avoidance. An accused invoking insanity admits to have committed the crime but claims that he or she is not guilty because of insanity. The testimony or proof of an accused’s insanity must, however, relate to the time immediately preceding or simultaneous with the commission of the offense with which he is charged. In the case at bench, the defense failed to overcome the presumption of sanity.

The respective testimonies of Dr. Villacorta and Dr. Gomez of the NCMH, as qualified expert witnesses, failed to support its claim of insanity. As observed by the CA, the mental examination on Isla taken four to six years after the incident happened in July 1997, in effect, showed that it could not be concluded with certainty that he was suffering from such psychosis immediately before or simultaneous to the commission of the crimes.

The expert witnesses themselves opined that their findings were not conclusive as to whether Isla was insane on that fateful day of July 21, 1997, as no examination was made on said day or for lack of information during that time.

This Court also agrees with the observation of the RTC as affirmed by the CA that Isla acted with discernment as can be deduced from his acts before, during and after the commission of the crimes with which he was charged.

 

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