039. People v.

Rafanan
November 21, 1991
Feliciano, J.
Short Version:
Rafanan was convicted of raping Estelita Ronaya. His defense was insanity
in the form of schizophrenia. The SC rejected his defense and upheld his
conviction, ruling that while he was, in fact, insane, he did not experience a
complete destruction of intelligence at the time of the act.
Facts:
In 1976, when Estelita Ronaya was 14 years old, she was hired by Ines
Rafanan, aka Baket Ines, mother of Policarpio Rafanan, as a househelper
at their house in Bgy. San Nicolas, Villasis, Pangasinan.
One night, on March 16, 1976, Ronaya was sent by Baket Ines to help
in the store in front of their house, which, at the time, was manned by
Policarpio. When Policarpio asked Ronaya to close the door of the store, he
suddenly pulled her inside the store and said, Come, let us have sexual
intercourse, to which Ronaya replied, I do not like.
Policarpio then held a 1 foot bolo to her throat, and forced himself
upon her, having sexual intercourse. After the filing of a complaint, and
trial, the CFI-Pangasinan convicted Rafanan of rape. Hence this appeal.
Issues:
1. WON the inconsistencies in testimony meant that the evidence was
hearsay. (No.)
2. WON Policarpios schizophrenia absolved him of criminal
liability. (No)
Ratio:
1. It was claimed that the testimony was incredible, because on direct
Ronaya claimed that she went home immediately, while on cross she
said she went home the next day. However, the inconsistencies related
to minor and inconsequential details which do not touch upon the
manner in which the crime had been committed and did not thus

affect the credibility of Ronaya. In all other respects, the commission

of the crime was not seriously disputed by Rafanan.
2. ****************LETS GET CRAZY**************
Policarpios main defense was that he was suffering schizophrenia
when he inflicted his violent intentions upon Estelita. At the trial court
level, the court ordered him confined at the National Mental Health
Hospital in Mandaluyong for observation and treatment. During this
time, four reports were made by Drs. Simplicio N. Masikip and Arturo
E. Nerit, each concluding that he was suffering from schizophrenia, as
symptomized by the ff.:
a. Sluggishness in movement, indifferent to interview
b. Carelessly attired with disheveled hair, staring vacuously through
the window
c. Indifference
d. Frequently answering Aywan ko, hindi ko alam.
e. Claiming to hear voices parang ibon, tinig ng ibon.
f. Constantly saying Oki naman to himself.1
g. Even when he was released because he had improved, still hearing
voices in his head and talking to himself.
As a result of the reports, the doctors concluded he was not in a condition to
stand court trial, until the 4th report, where he was cleared for trial.
Rafanans defense at trial was that he was already schizophrenic 1 to 2
years before he was confined, and was thus already insane at the time of the
rape.
This defense was based on Art. 12 of the RPC, which exempts imbeciles and
insane persons from criminal liability, unless the latter acted during a lucid
interval.
Insanity as a defense is subject to two standards, as set out in the
case of People v. Formigiones, to wit:
1. Test of cognitioncomplete deprivation of intelligence in
committing the act, and
2. Test of volitiontotal deprivation of freedom of the will.
Schizophrenia, formerly dementia praecox, is the most common form
of psychosis, symptomized by disturbance of association, affect and activity.
Previous cases where schizophrenia was interposed as a defense saw that
1 Which, judging from the fact hes from Pangasinan, and thus Ilocano, is
probably not what he was actually saying.

theory rejected by the Court. The evidence in these cases tended to show
that any impairment of the mental faculties was not so complete as to
deprive the accused of intelligence of the consciousness of his acts.
At trial, Dr. Jovellano, a psychiatrist who testified that she had
examined and treated Rafanan, said that he was not devoid of
consciousness at the time he perpetrated the rape and capable of palnning
the assault. Her testimony negated complete destruction of intelligence at
the time of the commission of the act. Thus, the defense of insanity cannot
be sustained.
The law presumes each man to be sane. A person accused of a crime
has the burden of proving his affirmative allegation of insanity. An inquiry
into the mental state of the accused should relate to the period immediately
before or at the very moement the act is committed. Rafanan failed to
discharge this burden. The testimonies of the doctors related to general
behavioral patterns of people afflicted with schizophrenia. The defense even
failed to present Dr. Masikip, who observed Rafanan during his
confinement.
However, while schizophrenia does not exempt Rafanan, it may be
considered as a mitigating circumstance as an illness which diminishes the
exercise of the offenders willpower without depriving him of the
consciousness of his acts.
Decision affirmed.
Gabe.