G.R. No.

138453 May 28, 2002

People of the Philippines vs. Melecio Robinos y Domingo

FACTS:

On March 25, 1995, the accused Melecio Robinos continuously stabbed his pregnant wife Lorenza Robinos
by his 8-inch double bladed knife which caused her death. On the same day, Benjamin, the brother of
Lorenza, also reported to the police that the accused had also killed their uncle and upon knowing that
Melencio had killed his sister, he then saw the accused and shouted at him “It’s good you would see how
your sister would die”. Upon the arrival of the police, they saw the accused embracing his dead wife and
when he was arrested, he admitted to their neighbor and barangay kagawad that he indeed killed his wife
while showing the bloodstained knife. Although the accused admitted his act of killing his own wife, he
seeks exoneration from criminal liability by invoking insanity as a defense.

ISSUE:

Whether or not Melecio Robinos can be exempted of criminal liability on grounds of insanity.

RULING:

No. The court rejected the defense of insanity as the evaluation of testimonies of the defense witnesses
hardly supports his claim of insanity. This is due to the bulk evidence that pertains to his unsound mental
condition already after the commission of the crime. It should be noted that insanity must have existed
at the time of the commission of the offense and not after of its commission. It could also be presumed
that the accused was insane at the time he was examined by the center and his insanity was only
contracted during his detention pending trial. It could be his conscience that has been troubling him
because of the realization of the gravity of the offense he had committed which may have conspired to
disrupt his mental equilibrium. Also, the findings of an expert Dr. Maria Mercedita Mendoza who had
examined him was conjectural and inconclusive as she didn’t have the opportunity to observe and assess
the behavior of the accused immediately before, during and immediately after the commission of the
offense. Thus, the proposed evidence by the defense was not able to prove that he had been completely
deprived of intelligence or freedom of will when he stabbed his wife to death and was not able to meet
the quantum of proof.