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People vs. Pantoja
G.R. No.223114, November 29, 2017
On July 22, 2010, at around 8:00 o'clock in the morning, Cederina and Pantoja-the accused-appellant were inside their house. She kept an eye on him from time to time but, eventually, she noticed that accused-appellant was gone. She went outside to look for him and noticed that the front door of the house where six-year-old AAA resided was open. She entered the house and, sensing that the cry emanated from upstairs, she went up.
Cederina then saw accused-appellant holding a knife and the victim sprawled on the floor, bloodied. She took the knife from him and asked him what happened. He did not respond and appeared dazed. She took him downstairs and out of the house where she called out for help for the victim. Nobody responded, until she saw Glenda, who immediately ran to their house when Cederina told her that her son AAA had been hurt.
After a while, barangay officials arrived and brought the accused-appellant with them. Cederina later learned that the victim had died.
Whether or not the accused-appellant must be exempt from criminal liability on the grounds of insanity
No. While insanity is one of the exempting circumstances enumerated in Article 12 of the Revised Penal Code (RPC), the courts have established a more stringent criterion for insanity to be exempting as it is required that there must be a complete deprivation of intelligence in committing the act, i.e., the accused is deprived of reason; he acted without the least discernment because there is a complete absence of the power to discern, or that there is a total deprivation of the will. For the defense of insanity to prosper, two (2) elements must concur: (1) that defendant's insanity constitutes a complete deprivation of intelligence, reason, or discernment; and (2) that such insanity existed at the time of, or immediately preceding, the commission of the crime.
The proof proffered by accused-appellant is insufficient to sustain his defense of insanity. The accused-appellant’s seemingly odd behavior of repeatedly going in and out of the house in the days prior to the incident does not, in any way, demonstrate his insanity. For purposes of exemption from criminal liability, mere behavioral oddities cannot support a finding of insanity unless the totality of such behavior indubitably shows a total absence of reason, discernment, or free will at the time the crime was committed. In addition, prior confinement at a mental institution does not, by itself, constitute proof of insanity at the time of the commission of the crime. The accused-appellant’s insanity was clearly not continuous, he had lucid intervals. Consequently, it is presumed that he was sane, or was in a lucid interval, at the time he committed the crime. Further, the fact that he was able to escape unnoticed from the institution and to return home by himself is indicative of reasonable intelligence and free will merely a week before the commission of the crime.