People vs. Tibon Case Digest G.R. No.
He said that he was only informed by
188320, June 29, 2010
Facts:
Honorio Tibon (accused-appellant) and his
common-law wife Gina Sumingot (Gina) lived
together as husband and wife. They had two
children, Keen Gist (KenKen) and Reguel
Albert (Reguel). They lived together with
Tibon’s parents and siblings on the third floor
of a rented house. Gina went to Hongkong to
work as a domestic helper, leaving their
children to Tibon’s custody. After some time,
Tibon heard from her sister who was also
working abroad that Gina was having an affair
with another man. After the revelation, he was
spotted drinking a lot and was seen hitting his
two children.
On the night of December 12, 1998, at around
11:30 p.m., accused-appellant’s mother and
his siblings (Zernan and Leilani), went to
Tibon’s room. They saw him with the two
children who appeared to be lifeless and bore
wounds on their bodies. When Tibon realized
that his mother and siblings had seen the
children lying on the floor he stabbed himself
on the chest with a kitchen knife and jumped
out of the window of their house. At the
hospital, accused-appellant survived and was
treated however, the children could no longer
be revived.
When Gina heard about the incident, she went
home immediately and confronted Tibon at the
hospital where he was confined. He confessed
to stabbing their children and begged her for
forgiveness.
In court, Tibon denied the charges against him
and raised insanity as defense. He said that he
could not recall what happened on the night he
allegedly stabbed his two children. He also
could not remember being taken to the
hospital.
his siblings that he had killed his two children,
causing him to jump off the window of their
house.
Issue:
Whether or not the exempting circumstance of
insanity applies to the accused-appellant’s
case?
Ruling:
No. Under Article 12 of the RPC “An imbecile
or an insane person, unless the latter has
acted during a lucid interval” is exempted from
criminal liability. Anyone who pleads the
exempting circumstance of insanity bears the
burden of proving it with clear and convincing
evidence. Testimony or proof of insanity must
relate to the time immediately preceding or
coetaneous with the commission of the
offense.
The medical records of Tibon with the National
Center for Mental Health (NCMH) is
inapplicable for such refers to his condition to
stand trial and not to his mental state
immediately before or during the commission
of the crimes.
Tibon’s behavior was triggered by jealousy
because of the revelation that his wife was
having an affair overseas. Uncontrolled
jealousy and anger are not equivalent to
insanity.
There is a vast difference between a genuinely
insane person and one who has worked
himself up into such a frenzy of anger that he
fails to use reason or good judgment in what
he does. We reiterate jurisprudence which has
established that only when there is a complete
deprivation of intelligence at the time of the
commission of the crime should the exempting
circumstance of insanity be considered.

The court considered Parricide as the

applicable law in this case. Under Article 264
Parricide is committed when: (i) a person is
killed; (ii) the deceased is killed by the
accused; (iii) the deceased is the father,
mother, or child, whether legitimate or
illegitimate, or a legitimate other ascendant or
other descendant, or the legitimate spouse of
the accused. Tibon was found guilty by this
Court with the punishment of reclusion
perpetua.