People v. Madarang
REITERATIONFacts
The Antecedents: Accused Fernando Madarang y Magno was charged with parricide for killing his wife, Lilia Madarang. The Information alleged that on September 3, 1993, the accused, with evident premeditation and treachery, armed with a bladed weapon, willfully, unlawfully, and feloniously attacked and stabbed his wife, Lilia M. Madarang, inflicting fatal wounds that caused her instantaneous death. Procedural History: At the arraignment, the accused refused to enter a plea, and the trial court entered a "not guilty" plea for him. Due to the accused's abnormal behavior observed in jail, the court ordered his transfer to the National Center for Mental Health (NCMH) for psychiatric evaluation. Initial examination revealed he was suffering from schizophrenia. After over two years of confinement and medication, he was discharged and found fit to stand trial. A reverse trial was conducted, with the defense presenting evidence on the claim of insanity. The trial court convicted the accused, finding him of sound mind at the time of the offense and failing to rebut the presumption of sanity. The court sentenced him to suffer reclusion perpetua. The Petition: The accused appealed his conviction, insisting he was completely deprived of intelligence at the time of the stabbing, rendering his act involuntary. He argued his unstable state of mind was evidenced by his lack of recollection of the incident, his behavior during the stabbing, the opinion of Dr. Tibayan regarding the possibility of prior schizophrenia, the absence of prior quarrels with his wife, and the lack of motive to kill his pregnant spouse.
Issue(s)
Whether the accused-appellant was suffering from insanity at the time of the commission of the crime of parricide, thereby exempting him from criminal liability. Whether the evidence presented by the defense sufficiently established the accused-appellant's alleged insanity at the time he killed his wife.
Ruling
The Supreme Court affirmed the trial court's decision, finding the accused-appellant guilty of parricide. The Court held that the defense failed to establish by convincing evidence that the accused was insane at the time of the commission of the crime. The conviction for parricide was affirmed in toto.
Ratio Decidendi
On the issue of insanity and its effect on criminal liability: The Court reiterated that for insanity to be an exempting circumstance, there must be a complete deprivation of intelligence in committing the act. This means the accused must have acted without the least discernment, with a total absence of the power to discern, or a total deprivation of the will. Mere abnormality of mental faculties does not exclude imputability. The Court noted that various tests for insanity have evolved, including the M'Naghten rule, the irresistible impulse test, the Durham "product" test, and the ALI "substantial capacity" test, but in the Philippines, the criterion remains stringent, requiring a complete absence of consciousness of the nature and consequences of his act or a total absence of the will to commit the same. The defense failed to demonstrate this complete deprivation of intelligence. On the sufficiency of evidence to establish insanity: The Court found the evidence adduced by the defense insufficient to establish the claim of insanity at the time the accused killed his wife. The diagnosis of schizophrenia was made months after the incident, and while Dr. Tibayan opined a high possibility of prior schizophrenia, he also stated that schizophrenics have lucid intervals. The defense failed to adduce proof that the accused was not in a lucid interval at the time of the offense. The Court found the appellant's arguments speculative and non-sequitur, such as his lack of recollection, the fear of witnesses, his non-repentant attitude, and the absence of prior quarrels, as these did not conclusively prove a complete deprivation of intelligence. The mother-in-law's testimony that she noticed nothing irregular in his behavior prior to the incident further weakened the defense's claim. The Court emphasized that evidence of insanity must relate to the time preceding or coetaneous with the commission of the offense.
Main Doctrine
The defense of insanity requires a complete deprivation of intelligence in committing the act, meaning the accused acted without the least discernment due to a total absence of the power to discern. Mere abnormality of mental faculties does not exclude imputability. The proof of insanity must relate to the time preceding or coetaneous with the commission of the offense.