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Insanity Plea: No Guarantee To Exempt An Individual From Criminal Liability

It is easy to use insanity plea as an escape from possible prosecution due to committing a criminal offense. Insanity is the best defense for an individual to avoid criminal liability. However, there are some conditions that must be taken into consideration. An insane person under Paragraph 1, Article 1 of the Revised Penal Code of the Philippines, the person is exempt from criminal liability if he or she acted during lucid interval. There should be clear and convincing evidence to prove the defendant's insanity. 

Art. 12. Circumstances which exempt from criminal liability. — the following are exempt from criminal liability:

1. An imbecile or an insane person, unless the latter has acted during a lucid interval.

When the imbecile or an insane person has committed an act which the law defines as a felony (delito), the court shall order his confinement in one of the hospitals or asylums established for persons thus afflicted, which he shall not be permitted to leave without first obtaining the permission of the same court.

Here's a court decision that did not accept insanity defense as a valid reason to absolve the perpetrator from the crime he committed: 

When insanity is used as a defense, the burden is on the defense as the appellant has to prove that the perpetrator is insane immediately before the commission of the crime or at the momen of its execution. There should be proof that the accused acted without discernment.

On November 26, 2002 at around 4 o'clock in the afternoon, Vicente Ringor was staying with his two-year old granddaughter, Maureen Joy Ringor, at the terrace of their house located at Villanueva, San Manuel, Isabela. Suddenly, Roger Ringor Umawid appeared and started attacking Vicente with a long bolo (panabas) without any reason. While Vicente was able to escape Umawid's blows, the latter nevertheless hit Maureen on her abdomen and back, causing her instant death. Upon seeing Maureen bloodied, Umawid walked away.

Thereafter, Umawid went to a nearby house which was only five meters away from Vicente's house where his nephew, Jeffrey Mercado, was sleeping. Awaken by the sudden noise, Jeffrey went outside only to see his uncle rushing to attack him with his panabas.

Jeffrey, along with his sister and cousin, rushed inside the house to seek for safety. However, Umawid was able to prevent Jeffrey from closing the door and the former barge into the house. Jeffrey crouched and covered his head with his arms to shield him from Umawid's impending attacks.

Umawid delivered fatal hacking blows to Jeffrey, causing the mutilation of the latter's fingers. Umawid only stopped upon seing Jeffrey, who was then pretending to be dead, leaning on the wall and blood-stained.

In court, Umawid set up the defense of insanity, but did not, however, take the witness stand to attest the same. Instead, he presented the testimonies of Dr. Arthur M. Quincina and Dr. Leonor Andres Juliana to support his claim. Dr. Quincina testifies that he evaluated Umawid's psychiatric condition in May 2002, February 2003, and on March 2003 and found that the latter was evident od psychotic symptoms. However, he could not tell with certainty whether Umawid was psychotic at the time of the commission of the crimes. On the other hand, Dr. Juliana failed to testify on Umawid's mental stare since she merely referred the latter to another doctor for further evaluation.


Whether or not the accused is exempted from criminal liablity due to insanity?


No. Under Article 12 of the RPC:

Article 12. Circumstances which exempt from criminal liabity - The following are exempt from criminal liability:

 1. An imbecile or an insane person, unless the latter has acted during a lucid interval.

The defense of insanity is in the nature of confession and avoidance because an accused invoking the same admits to have committed the crime but claims that he or she is not guilty because of insanity. The presumption is in favor of sanity, anyone who pleads the said defense bears the burden of proving it with clear and convincing evidence. Considering the case, the evidence must relate to the time immediately before or during the commission of the offense/s with which one is charged. Also, to support the defense of insanity, it must be shown that the accused had no full and clear understanding of the nature and consequences of his or her acts.

In this case, Umawid relied solely on the defense of Dr. Quincina and Dr. Juliana to support his claim of insanity. However, Dr. Quincina only examined Umawid six months before he committed the crime and three months and four months thereafter. Her findings as she admitted did not include Umawid's mental disposition immediately before or during the commission of the crimes. Also, given that Dr. Juliana failed to testify in favor of the accused, Umawid's defense of insanity remained unsubstiantiated, hence, he was properly adjudged by the RTC and CA as criminally liable.