People vs. Madarang

Insanity as an exempting circumstance requires proof of complete deprivation of intelligence in committing the act — the accused must be shown to have acted without the least discernment due to total absence of the power to discern or complete deprivation of the will; mere abnormality of mental faculties does not exclude imputability, and evidence of insanity must relate to the time preceding or coetaneous with the commission of the offense.

Fernando Madarang and Lilia Mirador were legally married and had seven children. Madarang worked as a seaman for sixteen years, employed on a United States ship until 1972 and then in Germany from 1973 until 1982. He thereafter returned to his family in Infanta, Pangasinan, and started a hardware store business, which failed; he also lost his entire fortune to cockfighting. The family was forced to live in the house of Lilia's mother, Avelina Mirador, as Madarang could no longer support them. Lilia was then pregnant with their eighth child and about to give birth.

Fernando Madarang and Lilia Mirador were legally married and blessed with seven children. Madarang worked as a seaman for sixteen years — on a United States ship until 1972, and in Germany from 1973 until 1982. He then returned to his family in Infanta, Pangasinan, and started a hardware store business. The venture failed, and he lost his entire fortune to cockfighting. In the latter part of July 1993, Madarang, Lilia, and their children were forced to stay in the house of Avelina Mirador, Lilia's mother, as Madarang could no longer support his family. Lilia was then heavy with their eighth child and about to give birth.

On September 3, 1993, at about 5:00 p.m., Madarang and Lilia had a squabble. Madarang was jealous of another man and accused Lilia of infidelity. In the heat of the fight and in the presence of their children, Madarang stabbed Lilia, resulting in her instantaneous death. Avelina Mirador was in the pigpen when she heard the children shouting and crying inside the house. She called out but received no reply. Her nephew barged into the house and brought the children out one at a time, leaving Madarang with Lilia. As he passed by Avelina, her nephew warned her: "You better run." Avelina then saw Madarang emerge from the house holding a bolo, and she scampered for safety. Avelina declared that during the period the family stayed in her house, she did not notice anything peculiar in Madarang's behavior suggesting mental illness, and she never saw the couple engage in any argument.

At the initial hearing on May 5, 1994, Madarang's counsel manifested that his client had been behaving abnormally inside the provincial jail. The trial court called Madarang to the stand, but he refused to answer any questions. The court ordered his transfer to the National Center for Mental Health (NCMH) for psychiatric evaluation. The initial examination revealed that Madarang was suffering from schizophrenia. He was confined and medicated for more than two years. Three psychiatric evaluations were conducted: the first, dated August 2, 1994, found him suffering from schizophrenia; the second, dated December 21, 1994, showed he was still afflicted; and the third, dated May 27, 1996, showed considerable improvement, leading to his discharge and recommittal to jail to stand trial. A reverse trial was then conducted, with the defense adducing evidence on the claim of insanity.

Madarang testified that he had absolutely no recollection of the stabbing incident. He could not remember where he was on that day or the whereabouts of his wife. It was only during one of the hearings, when his mother-in-law showed him a picture of his wife in a coffin, that he learned of her death. He claimed he did not know whether he suffered from any mental illness and did not remember being confined at the NCMH. Dr. Wilson S. Tibayan, a resident doctor at the NCMH, testified that schizophrenia is a mental abnormality characterized by impaired fundamental reasoning, delusions, hallucinations, and impaired cognitive, social, and occupational functions. He opined that Madarang's mental illness may have begun prior to his admission to the NCMH and that it was highly possible he was already suffering from schizophrenia prior to the commission of the crime. Dr. Tibayan also stated, however, that schizophrenics may have lucid intervals during which they can distinguish right from wrong.

• Complete Deprivation of Intelligence: Appellant insisted that at the time he stabbed his wife, he was completely deprived of intelligence, rendering his criminal act involuntary, as evidenced by his total lack of recollection of the incident.
• Behavior at the Time of the Stabbing: Appellant argued that his violent behavior on the fateful day — killing his wife, frightening his mother-in-law and her nephew into fleeing, and failing to recognize anyone — was symptomatic of schizophrenia, as described by Dr. Tibayan's testimony that a schizophrenic may go to violent and destructive extremes.
• Pre-existing Mental Illness: Appellant relied on Dr. Tibayan's opinion that there was a high possibility he was already suffering from insanity prior to the commission of the crime, attributing his loss of sanity to the bankruptcy of his hardware business and his dependence on his mother-in-law for support.
• Absence of Prior Conflict and Motive: Appellant contended that he and his wife never quarreled prior to that day, and that the marked change in his behavior confirmed mental disturbance. He urged that he had no motive to kill Lilia, who was scheduled to give birth three days prior to the killing, positing that jealousy is not a sufficient reason to kill a pregnant spouse.

• Insanity Defense: Whether the accused-appellant was insane at the time he committed parricide, such that he is exempt from criminal liability.

• Insanity Defense: No. The defense of insanity was not established, the evidence adduced being insufficient to show complete deprivation of intelligence at the time of the killing. The presumption of sanity was not rebutted, as no proof of abnormal behavior immediately before or coetaneous with the commission of the crime was presented.

• Insanity Defense: Philippine courts apply a stringent criterion for the exempting circumstance of insanity: there must be complete deprivation of intelligence in committing the act, meaning the accused is deprived of reason and acted without the least discernment, or there is total deprivation of the will. Mere abnormality of mental faculties does not exclude imputability. The issue of insanity is a question of fact, measurable only by the accused's behavior, and the proof of insanity must relate to the time preceding or coetaneous with the commission of the offense. In this case, although Madarang was diagnosed with schizophrenia months after the killing, none of the witnesses testified that he exhibited any of the myriad symptoms associated with schizophrenia immediately before or simultaneous with the stabbing. Dr. Tibayan himself acknowledged that schizophrenics have lucid intervals during which they can distinguish right from wrong, making it essential for the defense to prove that Madarang was not in a lucid interval at the time of the offense. The arguments advanced by the defense — lack of recollection, violent behavior, non-repentant attitude, absence of prior quarrels, and lack of motive — were deemed speculative and non-sequitur. The mother-in-law's testimony that she observed nothing abnormal in Madarang's behavior while he lived in her house further undermined the claim. Because the accused invoking the insanity defense admits committing the crime but claims he was insane at the time, he is tried solely on the issue of sanity; if found sane, conviction follows without a trial on the issue of guilt. As Madarang failed to establish his alleged insanity by convincing evidence, his conviction was affirmed.

• Insanity as an Exempting Circumstance — Under Philippine law, insanity exempts from criminal liability only when there is complete deprivation of intelligence in committing the act: the accused must be deprived of reason, acting without the least discernment, due to complete absence of the power to discern or total deprivation of the will. Mere abnormality of the mental faculties does not exclude imputability. The defense bears the burden of proving insanity, and the evidence must relate to the time preceding or coetaneous with the commission of the offense. Evidence of insanity after the fact may be accorded weight only if there is also proof of abnormal behavior immediately before or simultaneous with the commission of the crime. The Court applied this doctrine to reject Madarang's defense, as his schizophrenia diagnosis months after the killing, without corroborating evidence of abnormal behavior at or near the time of the act, was insufficient.

• Presumption of Sanity — Every person is presumed to be sane, and the burden of proving insanity rests on the accused invoking it. The Court relied on this presumption in affirming the conviction, as the defense failed to rebut it with convincing evidence.

• Lucid Interval — A schizophrenic may have lucid intervals during which the person is capable of distinguishing right from wrong. The existence of lucid intervals means that a diagnosis of schizophrenia does not per se establish insanity at the time of the offense; the defense must specifically prove that the accused was not in a lucid interval when the crime was committed.

• "In the Philippines, the courts have established a more stringent criterion for insanity to be exempting as it is required that there must be a complete deprivation of intelligence in committing the act, i.e., the accused is deprived of reason; he acted without the least discernment because there is a complete absence of the power to discern, or that there is a total deprivation of the will. Mere abnormality of the mental faculties will not exclude imputability." — This passage states the controlling Philippine standard for the insanity defense, distinguishing it from the more lenient Anglo-American tests discussed in the decision.

• "Although the appellant was diagnosed with schizophrenia a few months after the stabbing incident, the evidence of insanity after the fact of commission of the offense may be accorded weight only if there is also proof of abnormal behavior immediately before or simultaneous to the commission of the crime. Evidence on the alleged insanity must refer to the time preceding the act under prosecution or to the very moment of its execution." — This passage articulates the temporal requirement for proof of insanity, explaining why post-offense psychiatric diagnosis alone is insufficient.

• "An accused invoking the insanity defense pleads not guilty by reason thereof. He admits committing the crime but claims that he is not guilty because he was insane at the time of its commission. Hence, the accused is tried on the issue of sanity alone and if found to be sane, a judgment of conviction is rendered without any trial on the issue of guilt as he had already admitted committing the crime." — This passage defines the procedural posture and legal consequence of pleading the insanity defense, clarifying that admission of the act narrows the trial to the single issue of sanity.

• People vs. Aldemita, 145 SCRA 451 (1986) — Cited as controlling authority for the stringent Philippine standard requiring complete deprivation of intelligence for the insanity defense, and for the rule that evidence of insanity must relate to the time preceding or coetaneous with the commission of the offense.
• People vs. Ambal, 100 SCRA 324 (1980) — Cited in support of the proposition that mere abnormality of mental faculties does not exclude imputability.
• People vs. Renegado, 57 SCRA 275 (1974) — Cited alongside the line of cases establishing the Philippine standard for insanity as an exempting circumstance.
• People vs. Cruz, 109 SCRA 288 (1960) — Cited as part of the jurisprudential basis for the complete deprivation of intelligence requirement.
• People vs. Forigones, 87 Phil. 658 (1950) — Cited as early authority for the stringent insanity defense standard in Philippine jurisdiction.

• Article 246, Revised Penal Code — Defines and penalizes parricide, the crime for which Madarang was charged and convicted. The Information alleged that Madarang, with evident premeditation and treachery, armed with a bladed weapon, attacked and stabbed his legitimate wife Lilia, causing her instantaneous death. The trial court imposed reclusion perpetua, the penalty applicable at the time of the commission of the offense, as the death penalty was then suspended or abolished.

Davide, Jr., C.J., Kapunan, Pardo, and Ynares-Santiago, JJ., concurred.