“The Supreme Court said ‘evidence or proof of insanity… relate to the time immediately before, during, or after the commission of the offense’”
“Insanity, to be exempting, requires the complete deprivation of intelligence, not only of the will, in committing the criminal act. Mere abnormality of the mental faculties will not exclude imputability.” (Marie Claire Ruiz v. People of the Philippines, G.R. 244692, Oct. 9, 2025 citing People v. Haloc)
“Legal insanity, as an exempting circumstance, finds its basis under Article 12, paragraph 1 of the Revised Penal Code.” “The quantum of evidence needed to successfully prove legal insanity is only clear and convincing evidence following the case of People v. Austria (Austria).”
“A person’s mind can only be plumbed or fathomed by external acts. Thereby his [or her] thoughts, motives and emotions may be evaluated to determine whether his [or her] external acts conform to those of people of sound mind.” (Op cit. citing Austria)
Hence, “[t]he issue of insanity is a question of fact[,] for insanity is a condition of the mind, not susceptible [to] the usual means of proof. As no man [or woman] can know what is going on in the mind of another, the state or condition of a person’s mind can only be measured and judged by his [or her] behavior.” (Op cit. citing People v. Madarang)
“The accused must be so insane as to be incapable of entertaining a criminal intent. He [or she] must be deprived of reason, and must be shown to have acted without the least discernment because there is a complete absence of the power to discern or a total deprivation of freedom of the will.” (Op cit. citing Haloc)
The Supreme Court, “in People v. Pana (Pana), has crafted a three-way test to determine whether the defense of legal insanity is meritorious.
“[F]irst, insanity must be present at the time of the commission of the crime; second, insanity, which is the primary cause of the criminal act, must be medically proven; and third, the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act.” (Op cit.)
“Pana named a few such as, immediate surrender to the authorities, escaping arrest, display of remorse, and threatening the victim to avoid getting caught, which have been appreciated as proof that the accused understood the nature and consequence of the acts committed.” (Op cit.)
In the case of Marie Claire Ruiz (Ruiz) v. People of the Philippines, the accused Ruiz through counsel, raised the defense of schizophrenia after being charged with homicide for killing Paulita Bonifacio.
The Supreme Court, “in previous cases, appreciated schizophrenia as a medical condition which deprives a person of discernment, thus, falling under the exempting circumstance of legal insanity.” (Op cit.)
Ruiz’s “demeanor, reaction, and overt acts immediately after killing the victim show that she did not have a sliver of understanding as to what had just happened. She continued praying over the bloodied corpse of the victim while loudly chanting the words ‘This is the New Jerusalem, we will all be safe,’ with her hand inside the victim’s mouth.” (Op cit.)
She “failed to recognize her own father as she in fact shouted back and kicked Mr. Ruiz when the latter was trying to pull her hand out of the deceased’s mouth.”
Her “eyes were glaring (nanlilisik, in Mr. Ruiz’s own words) whenever she would look at her own father… [while being] completely naked and covered in blood…” (Op cit.)
As recognized by the Supreme Court, “evidence or proof of insanity… relate to the time immediately before, during, or after the commission of the offense.”
“Therefore, as long as an accused could proffer… proof of deprivation of intelligence either immediately before, during, or immediately after the commission of the crime, it shall be sufficient to meet the first test of Pana.” (Op cit.)
“Legal insanity, as an exempting circumstance, must be medically shown, unless there are extraordinary circumstances and there is no other evidence available.”
“The nature and degree of an accused’s mental illness can be best identified by medical experts equipped with specialized knowledge to diagnose a person’s mental health.” (Op cit.)
“Expert testimonies enable courts to verify if the behavior of the accused indeed resulted from a mental disease.” As shown by circumstances, Ruiz’s “insanity, which was the cause of the crime committed, is proven to be a medical condition. This definitively satisfies the second test in Pana” (Op cit.).
Ruiz’s “insanity was the sole cause of the commission of the crime as she was having a psychotic episode when she thought that the victim grew horns and turned into a demon.”
This led [her] to killing the victim as purportedly urged by the Virgin Mary’s voice inside [her] head which instructed her to put a cross in the victim’s heart…” (Op cit.)
