G.R. No. L-16381, December 30, 1961
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO FAUSTO Y TOMAS, defendant-appellant.

FACTS

The defendant-appellant, Antonio Fausto y Tomas, was convicted of murder for the killing of Dr. Antonio Casal. The undisputed facts established that on August 7, 1957, in Manila, appellant was seen by a witness stabbing the victim, who was lying on the ground. A police detective, responding to a call, found appellant at the scene shouting “Napatay ko siya” while holding a knife. Appellant was arrested, and he later re-enacted the crime for the police. The autopsy revealed the victim sustained 18 stab wounds.
At trial, the defense admitted appellant’s authorship of the crime but interposed the defense of insanity. Evidence showed appellant had been briefly confined at the National Mental Hospital over a year before the incident, diagnosed with schizophrenia, and was discharged against medical advice. Post-crime, a court-ordered observation resulted in a diagnosis that appellant suffered from schizophrenia, which existed before and after the crime. The defense presented testimonies to support his alleged mental incapacity at the time of the offense.

ISSUE

Whether or not appellant was insane at the time of the commission of the crime, thereby exempting him from criminal liability.

RULING

The Supreme Court affirmed the conviction, ruling that appellant was not insane at the time of the crime and was thus criminally liable. The legal presumption is that a person who commits a crime is sane, and the burden of proving insanity rests upon the defendant. The Court found the defense’s evidence insufficient to overcome this presumption. The prior confinement and subsequent diagnosis were not conclusive of his mental state at the precise moment of the killing.
The Court emphasized appellant’s lucid and deliberate actions before, during, and after the crime as indicative of sanity. He planned the killing a day in advance, traveled from Nueva Ecija to Manila, waited for the victim, made a final appeal before attacking, and understood the consequences, as shown by his declaration at the scene. His coherent re-enactment of the crime hours later further demonstrated his awareness. The Court also noted a clear motive: appellant blamed Dr. Casal for his unemployment after the doctor had him committed, which led to his dismissal. These factors collectively established that appellant acted with criminal intent and discernment. The crime was murder qualified by evident premeditation. The judgment of the trial court was affirmed in toto.