People vs.

Madarang
332 SCRA 99, G.R. No. 132319, May 12, 2000

Facts:

After having a quarrel, accused stabbed his wife causing her death. He was then charged with
Parricide. He claimed that he was in a state of insanity during incident for the accused cannot recollect
what happened. He further claimed that according to the doctor in National Center for Mental Health
(NCMH), wherein he was admitted, there was a high possibility that he was suffering from insanity prior
to his commission of the crime.

Issue:

The accused may claim exemption from liability for the crime he committed by pleading
insanity?

Held:

No, He is not exempt. In the Philippines, the Courts have strict criteria to follow for insanity as it
is required that there should be a complete deprivation of intelligence in committing the act. In other
words, the accused must be deprived of reason, acted with least discernment or absence of
discernment, and total deprivation of the will. The mere abnormality in the brain shall not exclude
imputability. The establishment of proving insanity requires an expert witness such as psychiatrists and
the like and the accused should be insane on committing the act.

In the case at bar the accused were diagnosed with schizophrenia at NCMH months after he
killed his wife. According to the medical books, schizophrenia is defined as inability to distinguish
between fantasy and reality, often accompanied by hallucinations and delusions. The arguments
advanced by the accused are speculative. None of the witnesses declared that he exhibited symptoms
during or before the act. Also to take notice that schizophrenia has a lucid interval which means they are
capable of distinguishing right from wrong.