People vs Aquino

Regalado, J.

Facts:

On the night of February 13, 1987, Armando Frias, a member of the Integrated
National Police of Urbiztondo, Pangasinan, received a report that there was a
victim of a crime in the clinic of a Dr. Padlan. He proceeded to the clinic and
found the victim, Carmelita Morado, 18 years old, lying down with her head
bleeding.

She told Frias that she was raped and struck with a stone by Juanito Aquino,
appellant herein. The victim was brought to the hospital where she died. The
medico legal report stated that she had the ff injuries
1. lacerated wound about 10 cm. at the front of the head;
2. skull fracture located on the front portion of the skull;
3. hemorrhage or bleeding on the left eye;
4. laceration of the brain;
5. laceration perineum; (sic)
6. laceration of the urethal (sic)

Juanito Aquino was arrested and detained. He was asked if he had a lawyer, as
he had none, Atty. Liliosa Rosario of the Citizens Legal Assistance Office was
contacted to assist him during the investigation. Aquino was informed of
constitutional rights, of his right to remain silent and to counsel. Appellant was
assisted by Atty. Rosario throughout the investigation.

After Aquino gave his statement, he was brought before a judge who had his
statement read back to him and translated to ensure that appellant understood
what was written. The judge had Aquino sign the statement in his presence.

After the complaint was filed but before arraignment, a Motion to Commit Aquino
to the National Center for Mental Health, was filed as Aquino was allegedly
manifesting unstable behavior with fits of violence. He was commited. Upon his
release a year later, he was arraigned, he pleaded not guilty and put up the
defense of insanity

Issue: whether or not appellant, who has invoked insanity as his defense, has
overcome the presumption of sanity? NO. The evidence adduced for appellant is too
nebulous and conjectural to be convincing.

The evidence adduced for appellant that he was insane immediately before or at the
very moment the crime was committed is too nebulous and conjectural to be convincing.
While Dr. Nicanor L. Echavez of the National Center for Mental Health described the
mental illness of the accused as "organic mental disorder with psychosis" he admitted
that a person suffering from insanity may know that what he is doing is wrong. The
same witness also testified that there is no possibility of appellant having lucid intervals,
but he, however, also observed that the mental illness of appellant came on and off.

The clinical case report also shows that appellant, when interviewed upon his admission
to the mental institution, recalled having taken 120 cubic centimeters of cough syrup
and consumed about 3 sticks of marijuana before the commission of the crime. This
admission substantially affirms his prior extrajudicial confession that he was under the
influence of marijuana when he sexually abused the victim and, on the occasion thereof,
killed her. It is, therefore, beyond cavil that assuming appellant had some form of mental
illness, it did not totally deprive him of intelligence. The presence of his reasoning
faculties, which enabled him to exercise sound judgment and satisfactorily articulate the
aforesaid matters, sufficiently discounts any intimation of insanity of appellant when he
committed the dastardly felonies. The annals of crime are replete with documented
records, and we are not without our share in this jurisdiction, where mental illness has
been feigned and invoked to provide a defense for the accused in a criminal
prosecution.

Arguments of parties:

Aquino: Presented four witnesses.

Nicanor Echavez; a psychiatrist at the National Center for Mental Health who
was in charge of the pavilion where appellant was committed. He conducted
physical, mental and psychological examinations and found him to be suffering
from mental disorder classified under organic mental disorder with psychosis.
When appellant Juanita Aquino committed the heinous act, the latter was totally
deprived of mind

Patricio Aquino, appellant's father, also testified that his son was already
mentally HI even when he was still young. Appellant was cruel to his brothers
and sisters, stole his mother's jewelry which he sold for a low sum, wandered
sometimes naked, and oftentimes not coming home for extended periods of time.
Appellant was previously confined at the Mental Hospital when he was caught
wandering around naked

Sgt. Raymundo Lomboy, the police officer charged with appellant's custody and
who transferred appellant for commitment to the National Center for Mental
Health, recalled that while appellant was in his custody, appellant acted
abnormally by singing, shouting, dancing and generally disturbing the other
inmates. He acted queerly by singing and shouting whenever he failed to drink
his medicine

Appellant himself was also presented as witness. He admitted he knew that he

has some mental illness and had undergone treatment like electric shock.

Prosecution: presented an array of witnesses to prove that appellant was lucid before
and after the crime was committed and that he acted with discernment.

Armando Frias testified that from the time of appellant's arrest and during the
investigation, appellant acted normally, and gave responsive answers to all the
questions propounded to him.

Angel Baysic, another member of the Integrated National Police in Urbiztondo,

Pangasinan whose house is located near the theatre being constructed, also
knew appellant who worked there as a laborer. He observed appellant to act
normally and was responsive to conversation.

Carlos Sabangon, one of the police officers who arrested appellant at the town
auditorium, testified that when appellant was arrested during the valentine dance,
he was appropriately dressed and behaved normally.

Eduardo Fernandez, a jail guard, was one on duty when appellant escaped from
prison on May 3, 1987. While appellant was confined in the provincial jail,
Fernandez did not observe any queer behavior from appellant.

Sanity is the normal condition of the mind - Sanity being the normal condition of the
human mind, the prosecution may proceed upon the presumption that the defendant
was sane and responsible when the act was committed. The presumption is always in
favor of sanity and the burden of proof of insanity is on the defense. The rule has
consistently been that when a defendant in a criminal case interposes the defense of
mental incapacity, the burden of establishing that fact rests upon him.

Definition of insanity - Insanity exists when there is a complete deprivation of

intelligence in committing the act, that is, the accused is deprived of reason, he acts
without the least discernment because there is complete absence of the power to
discern, or there is total deprivation of the freedom of the will. Mere abnormality of the
mental faculties will not exclude imputability.

How can insanity be determined - As no man can look into the mind of another, the
state of such mind can only be measured as the same is reflected in the actions of the
body it is created to govern. Thus, we have held that mind can only be known by
outward acts. Thereby we read the thoughts, the motives and emotions of a person and
come to determine whether his acts conform to the practice of people of sound mind.

Acts to show mental state, period - The period to which an inquiry into the mental
state of the accused should be directed is that transpiring immediately before and/or at
the very moment of the act or acts under prosecution.