G.R. Nos.

147674-75 March 17, 2004

People of the Philippines vs. Anacito Opuran

FACTS:

On November 19, 1988, 6:30 pm at Catbalogan, Samar, the accused Anacito Opuran stabbed Allan Dacles
who was lying at the bench. After more than an hour and a half, Demetrio Patrimonio was seen walking
on the National Highway of Catbalogan Samara but was later stabbed by the accused as he emerged from
where he was hiding. The accusations were denied by the accused, claiming that he was never out that
night when the crime happened and that he was only resting in his house when policemen came to arrest
him. Later, when the hearings resumed, an expert named Dr. Lyn Verona testified that she examined the
accused 3 times through interviews and confirmed her medical findings that the accused was psychotic
before and during the commission of the offense and even up to the present, that the accused was
suffering schizophrenia. However, when the trial court still held Opuran guilty of murder and homicide,
he contends that he was suffering from a psychotic disorder and was therefore, completely derived of
intelligence when he stabbed the victims.

ISSUE:

Whether or not the accused Anacito Opuran can use the exempting circumstance of insanity as a defense.

RULING:

No. Insanity must exist immediately before or during the moment of the commission of the act. Anyone
who pleads the exempting circumstance of insanity bears the burden of proving it however, the accused
failed to prove that he was insane at the precise moment or before the commission of the offense.
Although the accused has defense testimonies that he was brought to the National Center for Mental
Health due to difficulty of sleeping and talking irrelevantly, that he was prescribed thorazine and evadyne,
it should be noted that there was no proof that Anacito needed the medicine during the period where he
ran out of stock. There was also no intimation that he needed the medicine prior to the stabbing incident
and it was never shown that these drugs were for mental illness that deprives a person od reason. The
accused behavior of occasional silence, laughing, talking to oneself, etc. are not proof of a complete
absence of intelligence, because not every aberration of the mind or mental deficiency constitutes
insanity. As to what the court stated, a man may act crazy, but it does not necessarily and conclusively
prove that he is legally so. Furthermore, the results of Dr. Veronas examinations on Anacito were based
on incomplete or insufficient facts as she admitted examining the accused for only 3 sessions lasting one
to two hours each. Thus, Anacito Opuran was found guilty by the court and cannot use the exempting
circumstance of insanity as a defense to the crime that he had committed.