EXEMPTING CIRCUMSTANCES
PEOPLE VS DUNGO
Facts:
On March 16, 1987 between 2:00 and
3:00pm, the accused went to Mrs. Sigua's office
at the Department of Agrarian Reform, Apalit,
Pampanga. After a brief talk, the accused drew
a knife from the envelope he was carrying and
stabbed Mrs. Sigua several times. After which
he departed from the office with blood stained
clothes, carrying a bloodied bladed weapon.
The autopsy report revealed that the victim
sustained 14 wounds, 5 of which were fatal.
Rodolfo Sigua, husband of the deceased,
testified that sometime in February 1987, the
accused Rosalino Dungo inquired from him why
his wife was requiring so many documents from
him. Rodolfo explained to him the procedure at
the DAR.
The accused, in defense of himself, tried to
show that he was insane at the time of the
commission of the offense:
 Two weeks prior to March 16, 1987,
Rosalino's wife noticed that he appears to be
in deep thought always, maltreating their
children when he was not used to it before.
There were also times that her husband
would inform her that his feet and head were
on fire when in truth they were not.
 On that fateful day, Rosalino complained of
stomachache but they didn't bother to buy
medicine as the pain went away immediately.
Thereafter, he went back to the store. But
when Andrea followed him to the store, he
was no longer there. Worried, she looked for
him. On her way home, she heard people
saying that a stabbing occurred. She saw her
husband in her parents-in-law's house with
people milling around. She asked her
husband why he did the act, to which
Rosalino answered, "That's the only cure for
my ailment. I have cancer of the heart. If I
don't kill the deceased in a number of days, I
would die.” That same day, the accused went
to Manila.
Dr. Santiago and Dr. Echavez of the National
Center for Mental Health testified that the
accused was confined in the mental hospital, as
per order of the trial court dated Aug. 17, 1987.
Based on the reports of their staff, they
concluded that Rosalino was psychotic or
insane long before, during and after the
commission of the alleged crime and classified
his insanity as an organic mental disorder
secondary to cerebro-vascular accident or
stroke. But Dr. Balatbat who treated the
accused for ailments secondary to stroke, and
Dr. Lim who testified that the accused suffered
dorm occlusive disease, concluded that
Rosalino was somehow rehabilitated after a
series of medical treatment in their clinic.
Issue: Whether or not the accused was insane
during the commission of the crime charged.
Held:
No. For insanity to relieve the person of
criminal liability, it is necessary that there be a
complete deprivation of intelligence in
committing the act, that he acts w/o the least
discernment and that there be complete
absence or deprivation of the freedom of the will.
Under Philippine jurisdiction, there's no
definite test or criterion for insanity. However,
the definition of insanity under Sec 1039* of the
Revised Administrative Code can be applied. In
essence, it states that insanity is evinced by a
deranged and perverted condition of the mental
faculties, which is manifested in language or
conduct. An insane person has no full and clear
understanding of the nature and consequence
of his act.
Evidence of insanity must refer to the
mental condition at the very time of doing the
act. However, it is also permissible to receive
evidence of his mental condition for a
reasonable period before and after the time of
the act in question. The vagaries of the mind can
only be known by outward acts.
It is not usual for an insane person to
confront a specified person who may have
wronged him. But in the case at hand, the
accused was able to confront Mrs. Sigua. From
this, it can be inferred that the accused was
aware of his acts. This also established that the
accused has lucid intervals.
 Moreover, Dr. Echavez testified to the
effect that the appellant could have been aware
of the nature of his act at the time he committed
it when he shouted (during laboratory
examination) that he killed Mrs. Sigua. This
statement makes it highly doubtful that the
accused was insane when he committed the
act.

The fact that the accused was carrying an

envelope where he hid the fatal weapon, that he
ran away from the scene of the incident after he
stabbed the victim several times, that he fled to
Manila to evade arrest, indicate that he was
conscious and knew the consequences of his
acts in stabbing the victim.