People v. Catanyag
REITERATIONFacts
The Antecedents: Ariel Catanyag y Sta. Ana appealed his conviction for parricide by the Regional Trial Court of Antipolo, Rizal. The information alleged that on December 9, 1988, Ariel, being the husband of Elizabeth Catanyag y Calderon, willfully, unlawfully, and feloniously attacked and stabbed her several times with a knife, causing her death. The couple was legally married but separated prior to the incident. Elizabeth was staying at her sister Girlie Nery's house. On the afternoon of December 9, 1988, Ariel entered Girlie's house looking for Elizabeth. He found Elizabeth upstairs and a quarrel ensued when he wanted her to live with him again, which she refused. Elizabeth tried to hide in the comfort room, but Ariel followed her. Girlie witnessed Ariel close the comfort room door and heard Elizabeth moan. Girlie pushed the door and saw Ariel stabbing Elizabeth. Elizabeth, upon exiting the comfort room, tried to shield Girlie from Ariel, but Ariel turned and stabbed Elizabeth again. Ariel then chased Girlie's brother, Dante, out of the house and fled. Elizabeth died of severe hemorrhage within fifteen to twenty minutes after being taken to the hospital. Procedural History: The Regional Trial Court of Antipolo, Rizal, Branch 71, convicted Ariel Catanyag y Sta. Ana of parricide and sentenced him to reclusion perpetua, and to indemnify the heirs of the deceased in the amount of P50,000.00. The Petition: Ariel Catanyag appealed the decision, primarily arguing that he was suffering from insanity at the time of the killing.
Issue(s)
Whether the accused-appellant Ariel Catanyag y Sta. Ana was suffering from an exempting degree of insanity at the time he killed his wife.
Ruling
The appealed decision finding the accused Ariel Catanyag y Sta. Ana guilty beyond reasonable doubt of the crime of Parricide defined and penalized under Art. 246 of the Revised Penal Code, and sentencing him to suffer the penalty of reclusion perpetua, with the accessories provided by law, and to indemnify the heirs of the deceased, except himself, in the amount of P50,000.00 and to pay the costs, is hereby AFFIRMED in toto.
Ratio Decidendi
On Issue 1: The Supreme Court held that the appellant failed to present sufficient evidence to establish that he was suffering from an exempting degree of insanity at the time he killed his wife. The law presumes every man to be sane, and a person accused of a crime who pleads the exempting circumstance of insanity has the burden of proving it. For this exempting circumstance to be considered, it must be clearly established that the accused was completely deprived of reason when he committed the crime charged, meaning a complete deprivation of intelligence, absence of responsibility for his own acts, acting without the least discernment, or a total deprivation of freedom of the will. Mere abnormality of mental faculties does not exclude imputability, as reiterated in People vs. Rafanan citing People vs. Formigones. Dr. Canlas's medical findings, conducted two years after the crime, that the appellant suffered from an "organic mental syndrome" were insufficient because he admitted that the condition "could be transient or permanent" and that the appellant did not manifest the signs and symptoms during his testimony. Crucially, as per People vs. Aquino, the inquiry into the mental state of the accused must relate to the period immediately before or at the very moment the act is committed. The defense failed to positively show that the appellant was abnormal or partially/completely insane on December 8, 1988, to the extent that he was deprived of responsibility for his actions at that specific time.
Main Doctrine
The defense of insanity requires a clear and convincing showing that the accused was completely deprived of reason and acted without the least discernment at the time of the commission of the crime. Mere abnormality of mental faculties or a diagnosis made years after the commission of the offense is insufficient to establish the exempting circumstance of insanity.