G.R. No.

103974

September 10, 1993

PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARIEL CATANYAG Y STA. ANA, accused-appellant.
FACTS:
Respondent (Catanyag) and Elizabeth Calderon were legally married by Mayor Felix but were separated after 5 years.
Elizabeth was engaged in the business of buying and selling ready to wear clothes with her mother and was staying
at her sister Girlie Nerys house in Taytay Rizal.
Sometime in December 1988, at about 4:00 in the afternoon, respondent entered the house of Girlie without
permission. Girlie, who was fixing her wedding dress at that time, saw the respondent and asked him what he wanted
in which the respondent answered that he was looking for Elizabeth, but Girlie denied that Elizabeth is in the house.
However, the respondent insisted and started looking for Elizabeth around the house. The respondent chanced upon
Elizabeths niece who informed him that Elizabeth was upstairs. When Elizabeth was about to go down the stairs, she
saw the respondent and turned around to avoid him. However, the respondent followed him where they had a quarrel
as the respondent wanted to live with Elizabeth again. Elizabeth ran down the stairs and rushed to the comfort room
to hide but was again followed by the respondent. Girlie heard Elizabeth shouting and asking for help, however, when
she tried to open the door, it was blocked by the respondent who was stabbing Elizabeth with a batangas knife vente
nueve. After stabbing Elizabeth, the respondent proceeded against Girlie and pointed the knife towards her but was
prevented by Elizabeth; however, he went back to Elizabeth and started stabbing her again. Thereafter, the
respondent chased Dante (who came for rescue but was unarmed) out of their house and left the premises.
Elizabeth was rushed to the Angono District Hospital but later pronounced dead due to severe hemorrhage in the
emergency room.
A case of parricide was filed against Ariel Catanyag.
As a defense, tried to establish that the respondent was suffering from insanity at the time of the killing by providing
the testimony of Dr. Edgardo Canlas who conducted psychiatric and psychological examination on the respondent
wherein he submitted a report finding the respondent to be suffering from an organic mental syndrome. However,
his intelligence was found to be within the average level and physical and neurological examinations were within
normal limits.
RTC GUILTY OF PARRICIDE. Medical findings were not sufficient to establish Catanyags organic mental syndrome
was also his condition on December 9, 1988 when he killed his wife because the respondent was examined TWO
YEARS AFTER the commission of the crime.
Petitioner directly appealed to SC. (Can be done via notice of appeal because the penalty imposed was
imprisonment of reclusion perpetua.)
ISSUE:
Whether the respondent shall be exempted from liability due to insanity?
RULING:
No. The law presumes every man to be sane. A person accused of the crime who pleads the exempting circumstance
of insanity has the burden of proving it (Art. 12, Par. 1 on insanity, RPC). In order to consider this exempting
circumstance, it must be clearly established that the accused was completely deprived of reason when he committed
the crime charged.
It is necessary that there be a complete deprivation of intelligence in committing the act, that is, the accused is
deprived of reason; that there be no responsibility for his own acts; that he acts without the least discernment; that
there be a complete absence of the power to discern or that there be a total deprivation of freedom of the will. For
this reason, it was held that the imbecility or insanity at the time of the commission of the act should absolutely
deprive a person of intelligence or freedom of will, because mere abnormality of his mental faculties does not exclude
imputability.
What makes the appellants defense doubtful is Dr. Canlas admission during the trial that the organic mental
syndrome suffered by him "could be transient or permanent, depending on what caused it. Dr. Canlas also admitted
that at the time the accused testified, he did not manifest the signs and symptoms of such syndrome. Furthermore, it
was not positively shown that the appellant was abnormal or that he was partially or completely insane on December
8, 1988, when he killed his wife, so as to exempt him from responsibility for his action at the time.
An inquiry into the mental state of the accused should relate to the period immediately before or at the very moment
the act is committed. Dr. Canlas admitted that the examinations he made on the appellant in 1990 did not show that
his judgment and mental faculties were so totally impaired as to warrant the conclusion that his mental condition in
1988, when he committed the crime, and in 1990, when he took the tests, was the same so that his guilt or mental
competence at the time he killed his wife may not be reasonably doubted.
DOCTRINES:

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Defense of insanity - An insane person at the time of the commission of the crime shall be exempt from
criminal liability unless he acted during a lucid interval.
Mere abnormality of his mental faculties does not exclude imputability. The imbecility or insanity at the
time of the commission of the act should absolutely deprive a person of intelligence or freedom of will.
Burden of proof The presumption is always in favor of sanity, the burden of proof of insanity is on the one
(Catanyag) who is claiming the exemption.
Evidence It must be proved by the defense that insanity exists before or during the commission of the
crime by circumstantial evidence, beyond reasonable doubt, to be acquitted.