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Case: People vs.

Tibon
G.R. No.: 188320
Date: June 29, 2010

FACTS:
On or about the 12th day of December, 1998, in the City of Manila, Philippines, Honorio
Tibon, murdered KEEN GIST TIBON, 3 years of age and REGUEL ALBERT TIBON, 2 years of age,
both his legitimate children, by stabbing them several times on the chest with a bladed weapon,
thereby inflicting upon KEEN GIST and REGUEL ALBERT stab wounds which were the direct and
immediate cause of their death thereafter.

Honorio Tibon (accused-appellant) and his common-law wife Gina Sumingot (Gina) lived
together as husband and wife. They had two children, Keen Gist (KenKen) and Reguel Albert
(Reguel). Gina went to Hongkong to work as a domestic helper, leaving their children to Tibon’s
custody. After some time, it was revealed that Gina was apparently having an affair in Hong Kong,
Tibon then started drinking a lot and was seen hitting his two children.

At around 11:30 p.m., accused-appellant’s mother and his siblings discovered the
wounded and lifeless bodies of the children, Tibon stabbed himself on the chest with a kitchen
knife and jumped out of the window of their house. He confessed to stabbing their children and
begged for forgiveness to his wife.

In court, Tibon denied the charges against him and raised insanity as defense. He said that
he could not recall what happened on the night he allegedly stabbed his two children; could not
remember being taken to the hospital and that he was only informed by his siblings that he had
killed his two children, causing him to jump off the window of their house.

ISSUE:

Whether or not the exempting circumstance of insanity applies to the accused-appellant’s case?

RULING:

No. Under Article 12 of the RPC “An imbecile or an insane person, unless the latter has
acted during a lucid interval” is exempted from criminal liability. Anyone who pleads the
exempting circumstance of insanity bears the burden of proving it with clear and convincing
evidence. Testimony or proof of insanity must relate to the time immediately preceding or
coetaneous with the commission of the offense.

The medical records of Tibon with the National Center for Mental Health (NCMH) is
inapplicable for such refers to his condition to stand trial and not to his mental state immediately
before or during the commission of the crimes.
The court considered Parricide as the applicable law in this case. Under Article 264
Parricide is committed when: (i) a person is killed; (ii) the deceased is killed by the accused; (iii)
the deceased is the father, mother, or child, whether legitimate or illegitimate, or a legitimate
other ascendant or other descendant, or the legitimate spouse of the accused. Tibon was found
guilty by this Court with the punishment of reclusion perpetua. Tibon’s behavior was triggered
by jealousy because of the revelation that his wife was having an affair overseas. Uncontrolled
jealousy and anger are not equivalent to insanity.