People v. Madarang
People v. Madarang
Madarang
G.R. No. 132319
May 12, 2000
Facts:
Appellant was convicted of parricide for stabbing his wife, causing her death. Appellant alleges
he was in a state of insanity and claims he had no recollection of the stabbing incident. He insists
that he was deprived of intelligence , making his act involuntary. His psychiatric evaluation
revealed he was suffering from schizophrenia but after two years in the National Center for
Mental Health his condition improved thus, he was released. Trial proceeded.
Held: No. In the Philippines, 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 total deprivation of
the will. Mere abnormality of the mental faculties will not exclude imputability. The issue of
insanity is a question of fact. The state or condition of a mans mind can only be measured and
judged by his behavior. Establishing ones insanity requires testimony of an expert witness, such
as a psychiatrist. The proof must relate to the time preceding or coetaneous with the commission
of the offense with which he is charged. None of the witnesses declared that he exhibited any
of the symptoms associated with schizophrenia immediately before or simultaneous with
the stabbing incident of conviction is rendered without any trial on the issue of guilt as
he had already admitted committing the crime. As the appellant, in the case at bar, failed to
establish by convincing evidence his alleged insanity at the time he killed his wife, the court is
constrained to affirm his conviction.