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Effect on Crimes Article 12 Revise Penal Code

Art. 12. 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

US v. Vaquilar 27 Phil 88

Facts: The appellant, Evaristo Vaquilar was proven to have killed his wife and daughter in the
manner charged and to have wounded other persons with a bolo. His commission of these crimes
is not denied. The defendant did not testify but several witnesses were introduced in his behalf,
testifying that the defendant appeared to them to be insane at and subsequent to the
commission of the crimes. They also testified that he had been complaining of pains in his head
and stomach prior to the killing.

Issue: Whether or not Vaquilar who murder his wife and daughter with a bolo is liable for the
crime with the allegation of being insane.

Ruling: The appellant's conduct, as appears from the record, being consistent with the acts of
an enlarged criminal, and it not having been satisfactorily, shown that he was of unsound
mind at the time he committed the crimes, and the facts charged in each information having
been proven, and the penalty imposed being in accordance with the law, the judgments
appealed from are affirmed, with costs against the appellant.

Related Cases:
People vs. Mortimer (48 Mich., 37; 11 N. W., 776) - passion vs. insanity
The supreme court explain: But passion and insanity are very different things, and whatever
indulgence the law may extend to persons under provocation, it does not treat them as
freed from criminal responsibility. Those who have not lost control of their reason by mental
unsoundness are bound to control their tempers and restrain their persons, and are liable
to the law if they do not. Where persons allow their anger to lead them so far as to make
them reckless, the fact that they have become at last too infuriated to keep them from mischief
is merely the result of not applying restraint in season.
In People vs. Foy (138 N. Y., 664) Motive of crime
The court said: "The court very properly continued with an explanation to the jury that 'the heat
of passion and feeling produced by motives of anger, hatred, or revenge, is not insanity. The
law holds the doer of the act, under such conditions, responsible for the crime, because a large
share of homicides committed are occasioned by just such motives as these.' "
People v. Aldemita, 145 SCRA 451 (1986) Schizophrenia is covered by the term insanity
Schizophrenia as a chronic mental disorder characterized by inability to distinguish between
fantasy and reality and often accompanied by hallucinations and delusions, formerly called
dementia pracecox.
People v. Lacera, 69 Phil. 350 Malignant malaria is covered by the term insanity
One who is suffering from malignant malaria when she wounded her husband who died as a
consequence is not criminally liable, because such illness affects the nervous system and causes
among other such complication as acute melancholia and insanity at times.