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PEOPLE v.

DUNGO [199 SCRA 860 (1991)]


G.R. No. 89420. July 31, 1991.*
Nature: Automatic review of the decision of the RTC of Pampanga
convicting the accused of murder.
Facts: On March 16, 1987 between 2:00 and 3:00pm, the accused
went to Mrs. Sigua's office at the Department of Agrarian Reform,
Apalit, Pampanga. After a brief talk, the accused drew a knife from the
envelope he was carrying and stabbed Mrs. Sigua several times. After
which he departed from the office with blood stained clothes, carrying
a bloodied bladed weapon. The autopsy report revealed that the victim
sustained 14 wounds, 5 of which were fatal.
Rodolfo Sigua, husband of the deceased, testified that sometime in
February 1987, the accused Rosalino Dungo inquired from him why his
wife was requiring so many documents from him. Rodolfo explained to
him the procedure at the DAR.
The accused, in defense of himself, tried to show that he was insane at
the time of the commission of the offense:

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.

On that fateful day, Rosalino complained of stomachache but


they didn't bother to buy medicine as the pain went away
immediately. Thereafter, he went back to the store. But when Andrea
followed him to the store, he was no longer there. Worried, she
looked for him. On her way home, she heard people saying that a
stabbing occurred. She saw her husband in her parents-in-law's
house with people milling around. She asked her husband why he
did the act, to which Rosalino answered, "That's the only cure for my
ailment. I have cancer of the heart. If I don't kill the deceased in a
number of days, I would die. That same day, the accused went to
Manila.
Dr. Santiago and Dr. Echavez of the National Center for Mental Health
testified that the accused was confined in the mental hospital, as per
order of the trial court dated Aug. 17, 1987. Based on the reports of
their staff, they concluded that Rosalino was psychotic or insane long
before, during and after the commission of the alleged crime and
classified his insanity as an organic mental disorder secondary to
cerebro-vascular accident or stroke. But Dr. Balatbat who treated the

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.

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