VERDADERO V. PEOPLE (GR. No.

216021)

Syllabus Topic: Insanity Keywords: Drugstore stabbing

DOCTRINE:
Requisites of Insanity as a Valid Defense:
1. He was completely deprived of intelligence because of his mental condition or illness;
2. Such complete deprivation of intelligence must be manifest at the time or immediately before the
commission of the offense.

LAW/S OF THE CASE:

Article 12, RPC

Facts

Maynard Plata, his father, Romeo, and Ronnie Elaydo, reported and confronted Solomon Verdadero at a police
station for stealing the fan belt of their irrigation pump. On the way home, Maynard, Romeo, and Ronnie
stopped by a drug store. Maynard went inside the drug store; Romeo went to a nearby store; and Ronnie stayed
in the tricycle.

Maynard suddenly saw Verdadero stabbing Romeo with a Rambo knife, alerted by Ronnie’s shouts. When
Maynard tried to defend Romeo, Verdadero tried to attack him as well, but Maynard was able to defend himself
by using a small stool to hit Verdadero in the chest. Ronnie called for help. Romeo died.

As his defense, Verdadero stated that he was an outpatient of CMVC’s Psychiatric Department as he claimed he
heard voices and had insomnia. He was confined there for 2 months and was given medication for depression
and schizophrenia, a lifelong chronic disease. It was his 4th time being confined due to a relapse.

After the incident, Dr. Andres-Juliana and Dr. Pagaddu testified that Verdadero had suffered a relapse that day.
However, RTC convicted Verdadero of homicide, stating that he has not proven that he was not in a lucid
interval when he stabbed Romeo. CA concurred with these findings. Hence, this petition.

Issue

W/N Verdadero can claim the exempting circumstance of insanity? - YES

Holding

The petition is GRANTED. Verdadero is ACQUITTED of Homicide by reason of insanity.

 The expert opinion of Dr. Pagaddu, a psychiatrist, must be considered. She categorically testified that
Verdadero was suffering from a relapse of undifferentiated schizophrenia at the time of the stabbing
incident. She stated that the disorder influenced the impulse control and judgment of Verdadero.
Furthermore, even with medication, she stated that relapses may still occur.
 Maynard, who was also a neighbor of Verdadero, also testified that Verdadero’s behavior and
appearance when they met at the police station were not of his proper mind. His eyes were sharp and
reddish, and he acted somewhat drunk.
 Poor sleep and violent behavior are symptoms of a relapse.
 Verdadero was subsequently diagnosed to have suffered a relapse of schizophrenia. Generally, evidence
of insanity after the commission of the crime is immaterial. It, however, may be appreciated and given
weight if there is also proof of abnormal behavior before or simultaneous to the crime.
 Verdadero’s alleged insanity was raised as a defense at the earliest opportunity and was not a mere
afterthought.
 Verdadero is to be confined in a mental institution.