Dominic Oswald C.

Halili

PEOPLE VS. AQUINO G.R. No. 128887, January 20, 2000

Insanity; Mere abnormality of the accuseds mental faculties

does not exclude imputability; If the accused interposes the defense
of mental incapacity, the burden of establishing such fact rests upon
him.

FACTS: One fateful day, while Esmeralda (Victim) was in the house
and taking care of her sick child and her two other children, Edgardo
(Accused), their neighbor, came and asked for the whereabouts of
Valerio, Esmeraldas husband. Esmeralda informed Edgardo that
Valerio was in Olongapo.

Unsatisfied with their answer, Edgardo pulled out his knife and
initially tried to stab Esmeraldas son who was then playing on the
ground. Edgardo then stepped inside their house and attempted to
stab the daughter and so Esmeralda pulled her daughter aside.
Edgardo then went for the mother, Esmeralda. Edgardo repeatedly
stabbed Esmeralda in the stomach and chest areas. As a result, the
Esmeralda died.

Esmeralda suffered four (4) stab wounds at the xiphoid

process/chest area, two (2) of which were fatal as they penetrated the
thoracic cavity, causing lacerations on the anterior portion of the
superior lobe of the left lung.

Edgardo raised Temporary Insanity as a defense. He argued

that he was under the influence of a sudden attack of temporary
insanity.

ISSUE: Whether or not Edgardos defense of Temporary Insanity

is tenable.

HELD: NO, temporary insanity is not recognized in this

jurisdiction. Insanity, under Article 12 of the Revised Penal Code,
connotes that the accused must have been deprived completely of
reason and freedom of the will at the time of the commission of the
crime, or that he must have acted without the least discernment.
Mere abnormality of the accuseds mental faculties does not exclude
imputability. Moreover, EDGARDO was unable to substantiate his
claim. The law presumes every man to be sane. If the accused
interposes the defense of mental incapacity, the burden of
establishing such fact rests upon him. Insanity must be proved by
clear and positive evidence.