People vs. Madarang G.R. No. 132319. May 12, 2000 Ponente: Puno, J. Topic: Insanity/Imbecility: Basis of Exception FACTS: Fernando Madarang was charged with parricide for killing his wife Lillia Madarang. He refused to enter a plea during arraignment, and so was entered as “not guilty” in accordance to the rules of court. Counsel for t he accused manifested that his client had been observed exhibiting abnormal behavior. Court decided to transfer accused to t he National Center for Mental Health, after refusal to answer any question. Initial examination at NCMH revealed Fernando as suffering from schizophrenia. He was detained and medicated at the hospital. hospital. He was discharged discharged after 2 years, and recommitted at the provincial jail after being found fit to face charges. At the trial, it w as established that the accused was legally married to the victim, and their union resulted in 7 children. He worked as a seaman for 16 years, and thereafter started a hardware store business. His venture failed, and he lost his entire fortune to cockfighting. Fernando, his wife, and the children, were forced to move in with his mother-in-law ( Avelina Mirador), because he could no longer support his family. Lillia was also heavily pregnant with th their 8 child, and was about to give birth. On Sept. 3, 1993, Fernando and Lillia had because of jealousy. He was accusing her o f infidelity, and in the heat of the fight, stabbed her in front of the children. The children were heard shouting and crying, and were brought out of the house by Avelina Mirador’s nephew. She mentions seeing the accused emerge from the house, with a bolo. She declares no observation of anything peculiar about accused before the e vent, nor does she know of any reason why he killed Lillia, because she never saw the two engage in any argument while living with her. Accused declares no recollection r ecollection of any relevant events. He was sentenced with penalty of reclusion perpetua. Accused appealed, insisting his criminal act was involuntary. ISSUE: Whether or not evidence adduced by the defense is sufficient to establish appellant’s insanity, which would be a basis for being free from criminal liability. HELD: No. Philippine Courts have established a stringent criterion for insanity. To be exem pting, it is required that: (1) there must be a complete deprivation of intelligence in committing the act; (2) he acted without the least discernment because there is complete absence of power to discern; (3) or that there is total deprivation of will. Appellant was diagnosed to be suffering from schizophrenia AFTER he killed his wife. Record is also bereft of even a single account of abnormal or bizarre behavior prior to event. Evidence of insanity after the fact may be accorded weight only if there is a lso proof of abnormal behavior immediately before or simultaneous to commission of crime. Appellant failed to establish convincing evidence of alleged insanity at the time of killing his wife.
