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Two weeks prior to March 16, 1987, Rosalino's wife noticed that
he appears to be in deep thought always, maltreating their children
when he was not used to it before. There were also times that her
husband would inform her that his feet and head were on fire when
in truth they were not.
accused for ailments secondary to stroke, and Dr. Lim who testified
that the accused suffered dorm occlusive disease, concluded that
Rosalino was somehow rehabilitated after a series of medical
treatment in their clinic.
Issue: WON the accused was insane during the commission of the
crime charged.
Held: No. For insanity to relieve the person of criminal liability, it is
necessary that there be a complete deprivation of intelligence in
committing the act, that he acts w/o the least discernment and that
there be complete absence or deprivation of the freedom of the will.
Under Philippine jurisdiction, there's no definite test or criterion for
insanity. However, the definition of insanity under Sec 1039* of the
Revised Administrative Code can be applied. In essence, it states that
insanity is evinced by a deranged and perverted condition of the
mental faculties, which is manifested in language or conduct. An
insane person has no full and clear understanding of the nature and
consequence of his act.
Evidence of insanity must refer to the mental condition at the very
time of doing the act. However, it is also permissible to receive
evidence of his mental condition for a reasonable period before and
after the time of the act in question. The vagaries of the mind can only
be known by outward acts.
It is not usual for an insane person to confront a specified person who
may have wronged him. But in the case at hand, the accused was able
to Mrs. Sigua. From this, it can be inferred that the accused was aware
of his acts. This also established that the accused has lucid intervals.
Moreover, Dr. Echavez testified to the effect that the appellant could
have been aware of the nature of his act at the time he committed it
when he shouted (during laboratory examination) that he killed Mrs.
Sigua. This statement makes it highly doubtful that the accused was
insane when he committed the act.
The fact that the accused was carrying an envelope where he hid the
fatal weapon, that he ran away from the scene of the incident after he
stabbed the victim several times, that he fled to Manila to evade arrest,
indicate that he was conscious and knew the consequences of his acts
in stabbing the victim. (This was taken from the TC's decision).
Judgment: questioned decision AFFIRMED.