9. People vs.

Madarang

FACTS: After having a quarrel, accused stabbed his wife causing her death.
He was then charged with Parricide. He claimed that he was in a state of
insanity during the incident for the accused cannot recollect what
happened. He further claimed that according to the doctor in National
Center for Mental Health (NCMH), wherein he was admitted, there was a
high possibility that he was suffering from insanity prior to his commission
of the crime.

ISSUE: May the accused claim exemption from liability for the crime he
committed by pleading insanity?

HELD: No, he is not exempted. In the Philippines, the courts have strict
criteria to follow for insanity as it is required that there should be a
complete deprivation of intelligence in committing the act. In other
words, the accused must be deprived of reason, acted with least
discernment or absence of discernment, and total deprivation of the will.
The mere abnormality in the brain shall not exclude imputability. The
establishment of proving insanity requires an expert witness such as
psychiatrists and the like and the accused should be insane on committing
the act.

In the case at bar, the accused was diagnosed with schizophrenia at

NCMH months after he killed his wife. According to the medical books,
schizophrenia is defined as inability to distinguish between fantasy and
reality, often accompanied by hallucinations and delusions. The
arguments advanced by the accused are speculative. None of the
witnesses declared that he exhibited symptoms during or before the act.
Also, to take notice that schizophrenia has a lucid interval which means
they are capable of distinguishing right from wrong.