TSANG, Kelly C.

People v. Madarang
G.R. No, 132319
May 12, 2000

FACTS

On September 3, 1993, victim was stabbed by accused with evident premeditation and
treachery. On arraignment, accused counsel manifested that his client is behaving abnormally
inside the provincial jail. When the court asked him to stand in court, he refused to answer any
questions propounded by the court.

Upon initial examination of the accused, he was diagnosed with schizophrenia. The
accused was detained at the National Center for Mental Health for psychiatric evaluation to
determine his fitness to stand trial. After two years of confinement, the accused was discharged
from the NCMH and transferred to the provincial jail as he was already found fit to face the
charges against him.

According to his mother-in-law, Avelina Mirador, the accused was legally married and
they are blessed with seven children. The accused worked as a seaman for sixteen (16) years, he
was employed in a US ship for seven (7) years in a US ship and nine (9) years as a seaman in a
German ship until 1982. Thereafter he returned home in Infanta Pangasinan where he started a
hardware store business. His business however failed, and worse, he lost his fortune due to
cockfighting.

In July 1993, the accused and his family, stayed in his mother-in-law’s house as the
former cannot the family anymore; more so, the wife is pregnant and carrying their eighth baby.

In September 3, 1993, the couple had a quarrel where the accused was jealous of another
man and accusing his wife of infidelity. In the heat of the fight and the presence of his children,
Fernando stabbed Lilia, resulting to her death.

The doctor opined that the accused is suffering from schizophrenia and may have been
experiencing it even before the offense was committed.

ISSUE

Whether or not his plead for insanity would grant him innocence from the crime he
committed.

RULING
 The appellant insists that at the time he stabbed his wife, he was completely deprived of
intelligence, making his criminal act involuntary. His unstable state of mind could allegedly be
deduced from the following: He had no recollection of the stabbing incident. Hence, he was
completely unaware of his acts that fateful day and must have committed the crime without the
least discernment.
Second. His behavior at the time of the stabbing proved he was then afflicted with schizophrenia.
He cited the testimony of Dr. Tibayan that a schizophrenic may go into extremes — he may be
violent and destructive, or very silent and self-focused. He did not seem to recognize anybody
and could have inflicted injury to anyone. Third, the appellant also relies on Dr. Tibayan's
opinion that there was a high possibility that he was already suffering from insanity prior to his
commission of the crime on September 3, 1993. 17 The defense posits that his mental illness
may have been caused by his loss of fortune. His hardware business, which he started through 16
years of working as a seaman, went bankrupt. He ended up virtually dependent on his mother-in-
law for his family's support and all these may have been beyond his capacity to handle, which
was rather embarrassing.
Third, accused contends that he never got into a fight with his wife before the fateful day should
be considered. And lastly, the appellant urges that he never had the motive to kill his wife who
was to give birth to their eight child three days prior to the killing. Unless overpowered by their
control, nobody in his right mind would kill his wife who was carrying his child.

Even upon these circumstances, the Philippines has established a more stringent criterion
for insanity to be exempting as it required there must be complete deprivation of intelligence in
committing the act. Mere abnormality of the mental faculties will not exclude imputability. In
this case even though the accused was diagnosed to be suffering from schizophrenia when he
was committed to the NCMH after he killed his wife, the accused was not able to prove that his
insanity as he attributes it only to the loss his business and his dependence to his mother-in-law.
In fact, his mother-in-law declared that during the time she knew the appellant, there was nothing
irregular nor abnormal in his behavior that could suggest he was suffering from mental illness.

An accused invoking self-defense has already admitted the killing but claims he is not
guilty as he was insane at the time he committed the crime. The accused is tried and found to be
sane, a judgement of conviction is rendered without trial on the issue of guilt as he had already
admitted the commission of the crime. In the case at bar, the appellant failed to establish his
innocence with insanity upon committing the killing of his wife. Therefore the court has affirmed
the conviction of parricide.