People v Robinos

Appellant Melicio Robinos was charged with the complex crimeof parricide and unintentional abortion
and sentenced to death. The case stemmed sometime in March 1995, when appellant was heard
quarrelling with his 6 month pregnant wife, Lorenza, by their son Lorenzo Robinos. Thereafter, Lorezo
saw appellant with a double-bladed knife stab Lorenza on the right shoulder. Upon witnessing
appellant’s attack on his mother, Lorenzo immediately left their house and ran to his grandmother’s
house where he reported the incident. Appellant was apprehended by the police while embracing his
wife’s dead body and uttering “I will kill myself”. Autopsy report shows that the victim suffered 41 stab
wounds on diffetent parts of her body. Appellant does not refute the factual allegations of the
prosecution that he indeed killed his wife, but seeks exoneration from criminal liability by interposing
the defense of insanity.

Testimonies from several people: appellant’s 19 yr old son, a nurse, and 2 detention prisoners, testified
that appellant is seen isolating himself, murmuring alone, and sometimes looking, or staring on space
and without companion, laughing and crying.

In view of the penalty imposed by the trial court, this case was automatically elevated for review.

Issue: Whether accused may be exempted from criminal liability on the ground of insanity.

Held. No. Insanity presupposes that the accused was completely deprived of reason or discernment and
freedom of will at the time of the commission of the crime. A defendant in a criminal case who relies on
the defense of mental incapacity has the burden of establishing the fact of insanity at the very moment
when the crime was committed. Only when there is a complete deprivation of intelligence at the time of
the commission of the crime should the ex-empting circumstance of insanity be considered.

A perusal of the records of the case reveals that appellant’s claim of insanity is unsubstantiated and
wanting in material proof. Testimonies from both prosecution and defense witnesses show no
substantial evidence that appellant was completely deprived of reason or discernment when he
perpetrated the brutal killing of his wife. As can be gleaned from the testimonies of the prosecution
witnesses, a domestic altercation preceded the fatal stabbing. Thus, it cannot be said that appellant
attacked his wife for no reason at all and without knowledge of the nature of his action. Finally, the fact
that appellant admitted to responding law enforcers how he had just killed his wife may have been a
manifestation of repentance and remorse—a natural sentiment of a husband who had realized the
wrongfulness of his act. His behavior at the time of the killing and immediately thereafter is inconsistent
with his claim that he had no knowledge of what he had just done.

Valdadero V People

March 12, 2009, in the municipality of Baggao, Province of Cagayan. After a confrontation between the
appellant and the victim due to the latter’s accusation that Verdadero had stolen the fan belt of their
irrigation pump,the said accused SOLOMON VERDADERO armed with a Rambo knife, with intent to kill,
wilfully, unlawfully and feloniously attack, assault and stab ROMEO B. PLATA, thereby inflicting upon him
stab wounds on the different parts of his body which caused his death.
During the pretrial, accused invoked the defense of insanity. Defendant claimed that since 1999,
Verdadero had been an outpatient of CVMC’s Psychiatric Department as he claimed to hear strange
voices and had difficulty in sleeping. On July 21, 2003, he was diagnosed with schizophrenia and was
given medications to address his mental illness. Dr. Andres-Juliana opined that Verdadero suffered a
relapse on the day of the stabbing incident, as evidenced by his violent behaviour.

RTC Tuguegarao, charged the accused with homicide. The trial court posited that Verdadero was
unsuccessful in establishing that he was not in a lucid interval at the time he stabbed Romeo or that he
was completely of unsound mind prior to or coetaneous with the commission of the crime. CA affirmed
the decision of the RTC

Issue: whether the court erred in dismissing insanity as an exempting circumstance to exonerate
accused of crimininal liability.

Held: Yes.

Under Article 12 of the RPC, an imbecile or an insane person is exempt from criminal liability, unless the
latter had acted during a lucid interval. The defense of insanity or imbecility must be clearly proved for
there is a presumption that the acts penalized by law are voluntary In People v. Isla, the Court elucidated
that insanity must relate to the time immediately preceding or simultaneous with the commission of the
offense with which the accused is charged. Otherwise, he must be adjudged guilty for the said offense.
In short, in order for the accused to be exempted from criminal liability under a plea of insanity, he must
categorically demonstrate that: (1) he was completely deprived of intelligence because of his mental
condition or illness; and (2) such complete deprivation of intelligence must be manifest at the time or
immediately before the commission of the offense.

In the case at bench, it is undisputed that accused is suffering sfrom schizophrenia. A showing that an
accused is suffering from a mental disorder, however, does not automatically exonerate him from the
consequences of his act. Mere abnormality of the mental faculties will not exclude imputability. The
accused is duty-bound to establish with certainty that he was completely deprived, not merely
diminished, of intelligence at the time of the commission of the crime.

In order to ascertain a person’s mental condition at the time of the act, it is permissible to receive
evidence of his mental condition during a reasonable period before and after. Direct testimony is not
required nor are specific acts of disagreement essential to establish insanity as a defense. A person’s
mind can only be plumbed or fathomed by external acts. Thereby his thoughts, motives and emotions
may be evaluated to determine whether his external acts conform to those of people of sound mind. To
prove insanity, clear and convincing circumstantial evidence would suffice.

Guided by the precepts laid out by the above mentioned jurisprudence, the Court finds that Verdadero
sufficiently proved that he was insane at the time of the stabbing. His insanity may still be shown by
circumstances immediately before and after the incident. The finding of Verdadero’s insanity is
supported by the observations made by Maynard, a witness for the prosecution. On the day of the
stabbing incident, Maynard perceived that Verdadero was again of unsound mind noting that he had
reddish eyes and appeared to be drunk. Moreover, he was immediately transferred to the psychiatry
department because of his impaired sleep and to control him from harming himself and others. These
circumstances are consistent with Dr. Paggadu’s testimony that drinking wine, poor sleep and violent
behavior were among the symptoms of a relapse.

Accused-appellant acquitted and he is ordered confined in the National Center for Mental Health for
treatment.

People v Loreno

In the evening of January 7, 1978, in the Barangay of Magsaysay, Municipality of Libmanan, Province of
Camarines Sur, the accused, together with John Doe, Jose Doe, Richard Doe, Peter Doe, Charlie Doe, and
Ricky Doe, who are still at large, armed with firearms, robed Elias Monge in his home and with lewd
design committed sexual intercourse with Monica Monge, a virgin of 16 years old, and with Cristina
Monge, all against their will.

Appellants Eustaquio Loreno and Jimmy Marantal claimed that they acted under the compulsion of an
irresistible force and/or under the impulse of uncontrollable fear of equal or greater injury. They
admitted that they were in the house of Elias Monge on the night of January 7, 1978, but they were only
forced by a man wearing black sweater and his five companions who claimed to be members of the New
People’s Army (NPA) with the threat that if they did not obey, appellants and their families would be
killed.

Issue: Whether accused may be absolved from criminal liablity pursuant to Art 12 par 6 of the RPC.

Held. No.

A person who acts under the compulsion of an irresistible force, like one who acts under the impulse of
uncontrollable fear of equal or greater injury is exempt from criminal liability because he does not act
with freedom. The force must be irresistible to reduce him to a mere instrument who acts not only
without will but against his will. The duress, force, fear or intimidation must be present, imminent and
impending and of such a nature as to induce a well-grounded apprehension of death or serious bodily
harm if the act is not done. A threat of future injury is not enough. The compulsion must be of such a
character as to leave no opportunity to the accused for escape or self-defense in equal combat.

The records likewise revealed that on the two occasions Eustaquio Loreno brought Beata Monge to the
master’s room and the teacher’s room where he made her open the trunk and the “aparador” with her
keys and got the contents which he brought and poured on the floor of the sala, appellant Loreno acted
alone, without the threat and assistance of the man in dark sweater. And after the man in dark sweater
consummated his lust on Cristina Monge in the teacher’s room and seeing Cristina Monge still lying on
the floor, Loreno embraced her and tried to kiss and touch her private parts.

All these demonstrated the voluntary participation and the conspiracy of the appellants. The foregoing
acts, though separately performed from those of their unidentified companions, clearly showed their
community of interest and concert of criminal design with their unidentified companions