People of the Philippines, plaintiff-appellee, vs.

Fernando Madarang y Magno, accused-appellant

GR NO. 132319 May 12, 2000 Puno, J.
Ramirez

SUBJECT MATTER:
Exempting circumstances: Insanity and imbecility

DOCTRINE
For a defense of insanity to prosper, 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.

The testimony or proof of the accused's insanity must relate to the time preceding or coetaneous with the
commission of the offense with which he is charged.

LEGAL BASIS
ARTICLE 12(1). Circumstances Which Exempt from Criminal Liability. — The following are exempt from
criminal liability:

1. An imbecile or an insane person, unless the latter has acted during a lucid interval.

When the imbecile or an insane person has committed an act which the law defines as a felony (delito),
the court shall order his confinement in one of the hospitals or asylums established for persons thus
afflicted, which he shall not be permitted to leave without first obtaining the permission of the same
court.

ACTION BEFORE THE SUPREME COURT

Appeal from judgment of lower court

Plaintiff-appellee: People of the Philippines

Accused-appellant: Fernando Madarang y Magno

SUMMARY
Fernando Madarang was accused of parricide for killing his pregnant wife, Lilia Madarang, by stabbing
her with a bolo. He alleged insanity as his defense–claiming that he had absolutely no recollection of
the incident. Upon the order of the trial court, Fernando underwent psychiatric evaluations. His first
examination–which was conducted months after the stabbing incident–revealed that he was suffering
from schizophrenia. Hence, on July 4, 1994, he was committed to a psychiatric institution (the National
Center for Mental Health) where he received medication and treatment for his illness. His second
examination in December 1994 showed that he was still suffering from schizophrenia. On May 27, 1996,
after more than 2 years of confinement, he was discharged and recommitted to jail as the third
examination revealed he was already fit to face the charges against him.

The Court held that there was insufficient evidence to establish Fernando’s claim of insanity at the time
he killed his wife. There is a lack of evidence on record to show that the appellant was completely of
unsound mind prior to or at the time of the commission of the crime. The arguments offered by
appellant are merely speculative and non-sequitur. (see ruling below)

ANTECEDENT FACTS
● Fernando Madarang and Lilia Madarang were married and had 7 children.
 ● Fernando worked as a seaman for 16 years. Afterwards, he returned to his family in Pangasinan
and started a hardware store. However, his business venture failed and he lost his entire fortune
due to cockfighting and could no longer support his family.
● As a result, Fernando, his wife, and their children were forced to stay in the house of his
mother-in-law, Avelina Mirador. At that time, Lilia was pregnant with their eighth child and about
to give birth.
● On September 3, 1993, at about 5:00pm, Fernando and Lilia had a fight. He was jealous of
another man and accused Lilia of infidelity. In the heat of the fight and in the presence of their
children, Fernando stabbed Lilia and thereby caused her death.

ISSUE/S, HOLDING, AND RATIO

1. W/N Fernando Madarang can be exempted from criminal liability on the ground of insanity–NO

W/N
The Court held that there was insufficient evidence to establish Fernando’s claim of insanity at the
time he killed his wife. There is a lack of evidence on record to show that the appellant was
completely of unsound mind prior to or at the time of the commission of the crime. The arguments
offered by appellant are merely speculative and non-sequitur. The Court countered each argument,
as follows:

“For one, his claim that he has absolutely no recollection of the stabbing incident amounts to a mere
general denial that can be made with facility. The fact that Avelina and her nephew were frightened
at the sight of the appellant holding a bolo after he killed his wife does not, by any stretch of
imagination, prove that the appellant has lost his grip on reality on that occasion. Neither is the
appellant's seemingly non-repentant attitude immediately after he stabbed his wife an indicium of
his alleged insanity. Even criminals of stable mental condition take this non-remorseful stance.
Similarly, that the appellant and his wife were never seen quarreling prior to that fateful day does
not by itself prove the appellant's unstable mental condition. Neither can it be said that jealousy is
not a sufficient reason to kill a pregnant spouse. Our jurisprudence is replete with cases where lives
had been terminated for the flimsiest reason.”

Moreover, the Court gave credit to the testimony of Avelina Mirador (mother-in-law) that during the
time she knew Fernando, and while they lived in her house, she did not notice anything irregular or
abnormal in the appellant's behavior that could have suggested that he was suffering from any
mental illness. Since Fernando failed to prove and establish that he was insane at the time the crime
was committed, the SC affirmed the trial court’s decision; Fernando Madarang is guilty of parricide.

DISPOSITIVE
IN VIEW WHEREOF, the Decision of the trial court convicting the appellant of the crime of parricide is
AFFIRMED in toto