INSANITY NOT PROVEN

(4) PEOPLE vs. OPURAN

FACTS
1998: Anacito Opuran (OPURAN) stabbed and killed Allan Dacles (DACLES) and Demetrio
Patrimonio (PATRIMONIO).

Approx. 6:30 PM, DACLES was lying on a bench (outside the house of Bambi Herrera,
Bambi, herein witness, when OPURAN, from out of nowhere, stabbed DACLES five
times on different parts of the body.
Thereafter, DACLES ran indoors; OPURAN tried to pursue, but was prevented as Bambi
locked the doors.
OPURAN tried to force open and threw stones at door, before finally leaving. DACLES
died thereafter.
Approx. 8:00 PM same day as above, PATRIMONIO was walking along the highway when
OPURAN, suddenly emerging from his dark hiding place, stabbed PATRIMONIO four
times on different parts of the body.
OPURAN thenafter ran towards the house of Opurans.
PATRIMONIO was taken to the hospital but died the following day.

OPURANs alibi: That he was only resting in their house as he never went out at night. He denied
any stabbing.

OPURAN pleaded not guilty, and trial ensued OPURAN himself as first witness.
Subsequently, defense alleged insanity and motioned for postponement of trial for
OPURANs submittion to psychiatric examination:
After three sessions, a (short) medical certificate was issued commenting: (a) has
psychiatric disorder, (b) most likely psychotic before and during commission of crime.
Attending Psychiatrist on stand: schizophrenic, but not grossly insane.
Medical history: previously treated as outpatient with prescription medicine (not specified
for medicines purpose). Treatment ceased in 1990.

LEGAL ANTECEDENTS
RTC: (a) Homicide on account of DACLES, (b) Murder on account of PATRIMONIO.
OPURAN appealed with SC. Appellants brief: invoke exempting circumstance of insanity
(Art. 12 (1)); or alternatively, mitigating circumstance of illness as would diminish the
exercise of willpower (Art. 13 (9)).
ISSUE

WON OPURAN the exempting, or alternatively the mitigating, circumstance invoked in the
abovementioned appellants brief is tenable.

HELD

NO. The presumption is on sanity. Case law establishes very stringent standards for invoking
insanity: the defense must prove thru (a) clear and convincing evidence that there was (b)
complete absence of power to discern or total deprivation of will (c) immediately before and/or at
the time of the commission of the act such requirements OPURAN failed to meet:
Invoked insanity not at earliest opportunity, but only after testifying his alibis and denial.
There were only three sessions performed, medical certificate contained incomplete and
insufficient facts no supporting medical bases/data, did not demonstrate how conclusions
were arrived at, did not specify method.
Although previously treated, no indication what medicines prescribed were for; treatment
no longer obtained from 1990 to 1998.
No proof whatsoever to establish insanity (or even atleast mental illness, for purposes of
alternatively invoking Art. 13 (9)) immediately before or at the time of commission thus
presumption of sanity during time of commission stands.
OPURAN had consciousness of his acts at time of commission of crimes.