F a c t s : c o m p l a i n a n t e s t e l i t a r o n a ya w a s o n l y 1 4 ye a r s o l d w h e n h i r e d a s a

househelper by the mother of the accused. The accused policarpio rafaran

and his family lived with his mother in the same house. Policarpio was
married and has children. One evening, the mother of the accused called
complainant to help him close the door. When the complainant went near
him, he pulled her inside the store and raped her despite her resistance.
A f t e r t h a t , h e w a r n e d t h e c o m p l a i n a n t n o t t o t e l l a n yo n e a b o u t i t o r h e
w i l l k i l l h e r . T h e n e x t d a y, t h e f a m i l y o f t h e a c c u s e d k n e w w h a t
happened. Appellant claimed that he is suffering from schizophrenia when
he inflicted violent intentions to estelita. Trial court suspended the tria;
a n d o r d e r e d h i s c o n f i n e m e n t t o n a t i o n a l m e n t a l h o s p i t a l i n m a n d a l u yo n g .
A f t e r 2 ye a r s , h e w a s r e p o r t e d t o b e b e h a v e d a n d i n i m p r o v e d c o n d i t i o n
and in mental condition to stand court in trial. Trial of case resumed.

Issue: w/n the reason of insanity is suffic ient to relieve him from criminal
liability

Held: no. The allegation of insanity or imbecility must be clearly proved.

Without positive evidence that the defendant had previously lost his
reason or was demented, a few moments prior to or during the
perpetration of the crime, it will be presumed that he was in a normal
condition.