People vs. XXX

An accused who invokes insanity as an exempting circumstance under Article 12(1) of the Revised Penal Code must prove, by clear and convincing evidence, the three-way test set forth in People vs. Paña: (a) insanity must be present at the time of the commission of the crime; (b) insanity, which is the primary cause of the criminal act, must be medically proven; and (c) the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act. A documented history of psychiatric condition is not an element required to prove legal insanity, and prior psychiatric records cannot establish insanity at the precise time of the commission of the crime.

The case arose from an Information charging XXX with parricide under Article 246 of the Revised Penal Code for the death of her five-year-old daughter, AAA, whom she carried while jumping into the Pasig River. The accused-appellant and BBB were live-in partners, and AAA was their daughter. The defense raised the exempting circumstance of insanity under Article 12(1) of the Revised Penal Code, which exempts from criminal liability an imbecile or an insane person, unless the latter acted during a lucid interval. The Court noted that since the law presumes all persons to be of sound mind, insanity is the exception rather than the general rule, and it is incumbent upon the accused to prove insanity by clear and convincing evidence.

On the morning of January 19, 2010, XXX asked permission from her live-in partner, BBB, to go to xxxxxxxxxxx together with their five-year-old daughter, AAA. XXX then left with AAA. At around 8:30 a.m., Gaviola, who was scavenging at the side of xxxxxxxxxxx, Manila City, saw XXX letting her daughter stand at the side of the bridge. XXX then stood at the top of the bridge, grabbed her daughter, and had her stand on top of the bridge as well. Thereafter, Gaviola saw XXX jump off the xxxxxxxxxxx with her daughter, embracing the child as she jumped.

At the time, Moreno was scavenging along Pasig River near Fort Santiago on board his styrofoam banca. He heard shouting from people at the top of Delpan Bridge asking for help, saw XXX drowning, and immediately went to her. Moreno saved XXX from drowning and brought her to the "pantalan," leaving her in the care of persons there. Moreno was told that XXX jumped off the Delpan Bridge with her daughter, and while on his way home, he tried looking for the child to no avail. The following day, he heard people shouting that a child was found in the river, and he saw the lifeless body of the child, which turned out to be XXX's daughter, fetched from the river at a point very far from where XXX had jumped.

BBB was informed by a certain Russel Pranada that XXX was saved from Pasig River. BBB proceeded to the coastguard office and saw XXX but was not able to talk to her properly as she was being assisted to the hospital. BBB did not see his daughter with XXX; it was only the next day that he was informed by the coastguard that the body of his daughter was recovered.

XXX denied that she killed her daughter, testifying that she remembered walking with her daughter on xxxxxxxxxxx but could not remember anything after, and that she only regained consciousness when she was already floating in the water. She claimed she was not in her right mind at the time and only found out her daughter was dead when BBB informed her. The defense presented Dr. Bravo from the National Center for Mental Health, who testified that XXX was brought to the NCMH for consultation as an outpatient as early as August 13, 2010, and that based on the patient's history, XXX was evaluated in 2010, with findings contained in the Mental Status Examination Report dated March 8, 2013, stating that XXX was suffering from "schizophrenia." Dr. Bravo confirmed that after his own examination, XXX was indeed suffering from schizophrenia, as described in his Mental Assessment Report dated November 15, 2018, although he concluded she was competent to stand trial. The parties stipulated that Dr. Linn, together with Dr. Espinosa and Dr. Galindez, conducted mental status examinations and psychiatric evaluations of XXX on August 13, 2010, September 1, 2010, and April 26, 2013, and that the Report dated May 29, 2013 indicated XXX was found to be suffering from psychosis classified as schizophrenia.

The RTC found XXX guilty, holding that the prosecution established all the elements of parricide, with XXX's intent to cause harm demonstrated when she jumped off the bridge while embracing her daughter. The RTC brushed aside the claim of insanity, noting that XXX entered a plea of "not guilty" at arraignment and only raised insanity after the prosecution had rested its case, and that none of the defense witnesses declared that XXX exhibited symptoms associated with schizophrenia immediately before or simultaneous with the incident. The CA affirmed, similarly finding that XXX failed to present sufficient evidence of insanity at the time of the commission of the felony.

• Insanity as Exempting Circumstance: XXX argued that she was not herself and not in her right mind at the time of the incident, that she could not remember anything after walking with her daughter, and that she only regained consciousness when already floating in the water.
• Medical Evidence of Schizophrenia: XXX presented medical evidence, including the Mental Status Examination Report dated March 8, 2013, the Initial Report dated May 29, 2013, and the Mental Assessment Report dated November 15, 2018, showing she was suffering from schizophrenia, and argued that this exempted her from criminal liability under Article 12(1) of the Revised Penal Code.

• Sufficiency of Prosecution Evidence: The People of the Philippines, through the Office of the Solicitor General, maintained the findings of the RTC and the CA that the prosecution established all the elements of parricide, with XXX's intent to cause harm demonstrated when she jumped off the bridge while embracing her five-year-old daughter.
• Failure to Prove Insanity: The prosecution argued that XXX failed to present sufficient evidence to establish that she was suffering from insanity at the time of the commission of the felony, noting that none of the witnesses declared she exhibited symptoms associated with schizophrenia immediately before or simultaneous with the incident on January 19, 2010.

• Insanity as Exempting Circumstance: Whether XXX sufficiently established insanity to exempt her from criminal liability for the crime of parricide under Article 12(1) of the Revised Penal Code.
• Civil Liability Despite Acquittal: Whether XXX, although exempt from criminal liability, remains liable for civil damages to the heirs of the victim.

• Insanity as Exempting Circumstance: Yes. XXX was exempt from criminal liability, having medically proved that she was suffering from schizophrenia at the time of the commission of the crime, satisfying the three-way test in People vs. Paña: insanity was present at the time of the commission of the crime, it was medically proven, and its effect was the inability to appreciate the nature and quality or wrongfulness of the act.
• Civil Liability Despite Acquittal: Yes. Although exempt from criminal liability, XXX remained liable for civil damages, the RTC and CA having correctly awarded PHP 75,000.00 as civil indemnity, PHP 75,000.00 as moral damages, and PHP 75,000.00 as exemplary damages, with the Court additionally awarding PHP 50,000.00 as temperate damages.

• Insanity as Exempting Circumstance: The Court applied the three-way test established in People vs. Paña, which revisited the earlier doctrines in People vs. Formigones and People vs. Rafanan, Jr. Under Paña, insanity as an exempting circumstance requires: first, insanity must be present at the time of the commission of the crime; second, insanity, which is the primary cause of the criminal act, must be medically proven; and third, the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act. The Court found that XXX medically proved she was suffering from schizophrenia at the time of the commission of the crime. Dr. Linn testified that XXX had been experiencing symptoms as early as 2004, and the examining psychiatrists prepared the Mental Status Examination Report dated March 8, 2013, finding XXX suffered from schizophrenia, later confirmed by Dr. Bravo's examination in 2018. The Court rejected the RTC's conclusion that none of the witnesses testified that XXX exhibited symptoms immediately before or simultaneous with the incident, citing Ruiz vs. People for the proposition that having a documented history of a psychiatric condition is not an element required to prove legal insanity, and that prior psychiatric records could not establish insanity at the precise time of the commission of the crime. The Court further found that schizophrenia is a chronic mental disorder characterized by inability to distinguish between fantasy and reality, often accompanied by hallucinations and delusions, and is a medical condition which deprives a person of discernment. Dr. Linn's observations confirmed that XXX demonstrated paranoid ideation, felt that people were attempting, threatening, gossiping, and envying her, and that psychosis means a break with reality, impairing the patient's judgment. XXX's own testimony that she was "not herself" and "not in her right mind" further revealed her state of mind at the time of the incident. The Court concluded that XXX's mental state deprived her of the ability to appreciate the nature and wrongfulness of her act, thus exempting her from criminal liability under Article 12(1) of the Revised Penal Code.
• Civil Liability Despite Acquittal: The Court held that although XXX was exempt from criminal liability, she nevertheless remained liable for civil liability and other damages considering that a criminal act was nonetheless committed. Consistent with prevailing jurisprudence, the RTC and CA correctly awarded PHP 75,000.00 as civil indemnity, PHP 75,000.00 as moral damages, and PHP 75,000.00 as exemplary damages. The Court deemed it proper to additionally award temperate damages in the amount of PHP 50,000.00, which is proper when no evidence of actual damages such as burial and funeral expenses are presented in the trial court, as it cannot be denied that the heirs of the victim suffered pecuniary loss although the exact amount was not proved. The imposition of legal interest at the rate of 6% per annum on all monetary awards for damages from the date of finality of the ruling until full satisfaction was affirmed.

• Three-way test for insanity under People vs. Paña — The Court En Banc in People vs. Paña set forth new standards in establishing insanity as an exempting circumstance: (a) insanity must be present at the time of the commission of the crime; (b) insanity, which is the primary cause of the criminal act, must be medically proven; and (c) the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act. The Court applied this test in finding XXX exempt from criminal liability, holding that she medically proved her schizophrenia, which was present at the time of the incident and deprived her of the ability to appreciate the nature and wrongfulness of her act.
• **Test of cognition and test of volition under People vs. Rafanan, Jr. ** — The Formigones doctrine was expounded in People vs. Rafanan, Jr., resulting in the formulation of two distinguishable tests: (a) the test of cognition, which requires "complete deprivation of intelligence in committing the criminal act," and (b) the test of volition, which requires "total deprivation of freedom of the will." The Court noted that Paña revisited Formigones and succeeding cases, setting forth the new three-way test.
• Insanity as complete deprivation of reason or discernment — Since 1950, the Court's ruling in People vs. Formigones had remained relatively undisturbed, holding that insanity as an exempting circumstance should be "deprived completely of reason or discernment and freedom of the will at the time of committing the crime." The Court applied this principle in the context of the Paña three-way test.
• Insanity must be proven by clear and convincing evidence — Since the law presumes all persons to be of sound mind, insanity is the exception rather than the general rule. In claiming insanity, an accused admits the commission of the criminal act but seeks exemption from criminal liability due to lack of voluntariness or intelligence. Thus, it is incumbent upon the accused to prove insanity by clear and convincing evidence, and considering that insanity refers to an individual's state of mind, it can only be proven through overt acts.
• Medical proof of insanity — In order to prove insanity, the same must be shown medically, unless there are extraordinary circumstances and there is no other evidence available. While procedural rules allow ordinary witnesses to testify on the mental sanity of a person with whom they are sufficiently acquainted, reports and evaluation from medical experts have greater evidentiary value in determining an accused's mental state, as the nature and degree of an accused's mental illness can be best identified by medical experts equipped with specialized knowledge to diagnose a person's mental health.
• Documented psychiatric history not an element of legal insanity — Citing Ruiz vs. People, the Court stressed that having a documented history of a psychiatric condition is not, and should never be, an element required to prove legal insanity. Prior psychiatric records could not establish insanity at the precise time of the commission of the crime because, for obvious reasons, medical reports from doctors prior to the commission of the crime cannot be considered as having been rendered immediately before the commission of the crime, unless the facts clearly establish so.

• "Insanity is defined as 'a manifestation in language or conduct of disease or defect of the brain, or a more or less permanently diseased or disordered condition of the mentality, functional or organic, and characterized by perversion, inhibition, or disordered function of the sensory or of the intellective faculties, or by impaired or disordered volition.'" — This passage defines insanity for purposes of the exempting circumstance under Article 12(1) of the Revised Penal Code, and is the foundational definition upon which the Court's analysis rests.
• "Thus, Paña has set forth new standards in establishing insanity as an exempting circumstance using the three-way test: first, insanity must be present at the time of the commission of the crime; second, insanity, which is the primary cause of the criminal act, must be medically proven; and third, the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act." — This excerpt articulates the controlling three-way test for insanity, which the Court applied to find XXX exempt from criminal liability.
• "On this score, the Court stressed in Ruiz v. People, that having a documented history of a psychiatric condition is not, and should never be, an element required to prove legal insanity. Prior psychiatric records could not establish insanity at the precise time of the commission of the crime because, for obvious reasons, medical reports from doctors prior to the commission of the crime cannot be considered as having been rendered immediately before the commission of the crime, unless the facts clearly establish so." — This passage addresses the RTC's error in requiring evidence of symptoms immediately before or simultaneous with the incident, clarifying that prior psychiatric records are not an element of legal insanity.
• "Schizophrenia has been described as a chronic mental disorder characterized by inability to distinguish between fantasy and reality, and often accompanied by hallucinations and delusions. It is a medical condition which deprives a person of discernment." — This excerpt describes schizophrenia and its effect on discernment, supporting the Court's conclusion that XXX's mental state deprived her of the ability to appreciate the nature and wrongfulness of her act.

• People vs. Paña, 890 Phil. 533 (2020) — Controlling precedent that set forth the three-way test for establishing insanity as an exempting circumstance, which the Court applied in finding XXX exempt from criminal liability.
• People vs. Formigones, 87 Phil. 658 (1950) — Followed and revisited; established the doctrine that insanity as an exempting circumstance should be "deprived completely of reason or discernment and freedom of the will at the time of committing the crime."
• People vs. Rafanan, Jr., 281 Phil. 66 (1991) — Followed and expounded; formulated the test of cognition and test of volition, and described schizophrenia as a chronic mental disorder characterized by inability to distinguish between fantasy and reality.
• Ruiz vs. People, 959 Phil. 280 (2024) — Followed; held that having a documented history of a psychiatric condition is not an element required to prove legal insanity, and that an accused who is exempt from criminal liability nevertheless remains liable for civil damages.
• People vs. Jugueta, 783 Phil. 806 (2016) — Followed; cited as prevailing jurisprudence for the awards of civil indemnity, moral damages, and exemplary damages, and the imposition of legal interest at 6% per annum.
• People vs. Bragais, 956 Phil. 694 (2024) — Followed; cited for the proposition that temperate damages are proper when no evidence of actual damages such as burial and funeral expenses are presented, as the heirs suffered pecuniary loss although the exact amount was not proved.
• People vs. Delos Santos, Jr., 889 Phil. 482 (2020) — Followed; cited for the award of temperate damages in criminal cases.
• People vs. Comboy, 782 Phil. 187 (2016) — Followed; cited for the principle that an appeal in criminal cases throws the whole case open for review, and the appellate court has the competence to examine records, revise the judgment appealed from, increase the penalty, and cite the proper provision of the penal law.
• People vs. Ygoy, 858 Phil. 1026 (2019) — Followed; cited for the same principle regarding the appellate court's competence in criminal appeals.
• Villarba vs. Court of Appeals, 874 Phil. 84 (2020) — Followed; cited for the doctrine that factual findings of the trial court are entitled to great weight and respect, especially when affirmed by the appellate court.
• Concha vs. People, 841 Phil. 214 (2018) — Followed; cited for the exceptions justifying factual review, including when the judgment of the CA is based on a misapprehension of facts.
• People vs. Calines, 952 Phil. 576 (2024) — Followed; cited for the definition of insanity.
• People vs. Ambal, 188 Phil. 372 (1980) — Followed; cited for the definition of insanity.
• People vs. Aldemita, 229 Phil. 448 (1986) — Followed; cited for the presumption of sound mind and that insanity is the exception rather than the general rule.
• People vs. Renegado, 156 Phil. 260 (1974) — Followed; cited for the principle that in claiming insanity, an accused admits the commission of the criminal act but seeks exemption from criminal liability due to lack of voluntariness or intelligence.
• People vs. Austria, 328 Phil. 1208 (1996) — Followed; cited for the requirement that insanity must be proven by clear and convincing evidence.
• People vs. Bonoan, 64 Phil. 87 (1937) — Followed; cited for the principle that insanity can only be proven through overt acts.

• Article 246, Revised Penal Code — The provision defining and penalizing parricide, under which XXX was charged and convicted by the RTC and CA, and from which she was acquitted on appeal on the ground of legal insanity.
• Article 12(1), Revised Penal Code — The provision exempting from criminal liability an imbecile or an insane person, unless the latter acted during a lucid interval, and ordering the confinement of the imbecile or insane person in one of the hospitals or asylums established for persons thus afflicted, who shall not be permitted to leave without first obtaining the permission of the same court. The Court applied this provision in exempting XXX from criminal liability and ordering her confinement at the National Center for Mental Health.

• Caguioa, J. (Chairperson) — Concurred; the Court noted that Associate Justice Alfredo Benjamin S. Caguioa astutely pointed out that a reexamination of the rulings of the RTC and the CA in relation to the evidence on record would yield to a different conclusion.
• Inting, J. — Concurred.
• Dimaampao, J. — Concurred.
• Singh, J. — Concurred.