Insanity vs passion

Every person is presumed to be of sound mind. He who claims insanity or imbecility as an exempting circumstance for his criminal liability must clearly prove by positive evidence such insanity. This case tells us when an accused person can be considered legally insane.

The accused involved here is Ryan. Ten years before the incident, Ryan was brought to the National Mental Hospital after he had shown unusual conduct such as looking blankly at a distance, hitting his wife or banging her head on the wall for no reason and having sleepless nights.

Ryan was confined at the National Mental Hospital for four months due to schizophrenic form disorder. Thereafter, he was released and lived with his mother and two children. His condition did not improved though. In fact, ten years after his confinement, he again exhibited the same unusual behavior as he had shown ten years before, thus prompting his sister, Lucille, to refer him to a psychologist-friend The psychologist conducted a test on Ryan and results revealed that he was suffering only from mild depression because of problems encountered in life and things around him.

Four months after such test, the incident happened. Ryan went to the house of his sister Lucille to watch TV. At that time, a party was going on celebrating the victory of the basketball team of Lucille’s son, Timmy. When he arrived, Timmy, Mike, Bobby, Denver and three others were drinking. During the celebration, Ryan and Mike started to dance the cha-cha in the spirit of fun while the others clapped their hands. Later on, Ryan left followed by Mike and Bobby. While the two were walking with Mike ahead of Bobby, Bobby saw Ryan, who was waiting behind a Chico tree along the way, suddenly pounced and stabbed Mike with a balisong. Mike and Ryan then grappled and Mike was able to extricate himself and ran away. But Ryan caught up with him and stabbed Mike once more at the back. Mike tried to get up and run but again fell down. Ryan stabbed him once more in the chest. Ryan stabbed Mike seven times before he fled.

Aside from Bobby, Denver also witnessed the incident. He was then urinating when he heard Lucille shouting to Alfred "pihadong makukulong ka, sinaksak mo si Mike". When he turned where the shout came from, he saw Mike running towards him pursued by Ryan. He tried to hug Mike but he fell to the ground fatally wounded. Then he saw Ryan flee.

When charged of murder, Ryan sets up insanity as his defense. He cited his previous hospitalization at the National Mental Hospital and the latest psychological test conducted on him four months before the incident. Was Ryan exempt from liability because of insanity?

No. The test results of the psychologist do not prove the alleged insanity of Ryan. The law (Art. 12(1) RPC) requires a complete deprivation of rationality in committing the act, i.e., that the accused be deprived of reason, that there be no consciousness of responsibility for his acts, or that there be complete absence of the power to discern. The report does not support the claim that Ryan could not distinguish right from wrong. Care must be taken to distinguish between lack of reason (insanity) and failure to use reason or good judgment due to extreme anger (passion). Mere mental depravity or moral insanity, so called, which results not from any disease of mind but from a perverted condition of the moral system where the person is mentally sane, does not exempt one from responsibility for crimes committed under its influence. There must be complete deprivation of intelligence – not only of the will – in committing the criminal act. Mere abnormality of the mental faculties does not exclude criminal culpability. In this case, the psychological test shows that Ryan was suffering only from mild depression but his mental activity is functioning on the normal level. Ryan was sentenced from ten years and one day up to 17 years, four months and one day in jail (Pp. V. Alberto Medina, G.R. 113691, Feb. 6, 1998).

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