G.R. No. 103974 September 10, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARIEL CATANYAG Y STA. ANA, accused-appellant.

FACTS

Accused-appellant Ariel Catanyag y Sta. Ana appealed his conviction for parricide by the Regional Trial Court of Antipolo, Rizal, Branch 71. The information alleged that on December 9, 1988, in Taytay, Rizal, he willfully, unlawfully, and feloniously attacked and stabbed his wife, Elizabeth Catanyag y Calderon, with a Batangas knife, causing her death. The couple, legally married in 1983, had separated by 1988, with Elizabeth staying at her sister Girlie Nery’s house. On the afternoon of December 9, 1988, the accused entered Girlie’s house without permission, looking for Elizabeth. After finding her, a quarrel ensued as he wanted her to live with him again, but she refused. Elizabeth ran to hide in the comfort room, but the accused followed. Girlie witnessed the accused stabbing Elizabeth inside the comfort room. When Elizabeth struggled out, the accused stabbed her again. Elizabeth was taken to the hospital but died of severe hemorrhage. The defense presented Dr. Edgardo Canlas, who conducted a psychiatric examination in 1990 and found the accused suffering from an “organic mental syndrome” characterized by irritability and poor impulse control. The trial court convicted the accused, sentencing him to reclusion perpetua and ordering him to indemnify the heirs.

ISSUE

Whether the accused-appellant was completely deprived of reason due to insanity at the time of the killing, thereby exempting him from criminal liability under Article 12 of the Revised Penal Code.

RULING

The Supreme Court affirmed the trial court’s decision, holding that the accused-appellant failed to prove the exempting circumstance of insanity. The law presumes every person to be sane, and the burden of proving insanity lies with the accused. To be exempt, it must be clearly established that the accused was completely deprived of intelligence, reason, or freedom of will at the very moment of the crime. The Court found the defense’s evidence insufficient. Dr. Canlas’s report from 1990 did not conclusively prove that the accused’s “organic mental syndrome” existed on December 9, 1988, when the crime was committed. Dr. Canlas admitted the syndrome could be transient or permanent and that the accused did not manifest its symptoms at the time of his testimony. The inquiry into mental state must relate to the period immediately before or at the very moment of the act. The evidence did not show a total impairment of the accused’s mental faculties at the time of the killing. Therefore, the conviction for parricide was upheld.