G.R. No. 132319 May 12, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FERNANDO MADARANG y MAGNO, accused-appellant.

FACTS

Accused-appellant Fernando Madarang was charged with parricide for stabbing his wife to death on September 3, 1993. During arraignment, he refused to plead, prompting the court to enter a plea of not guilty. His counsel later manifested his abnormal behavior in jail, leading the court to order his psychiatric evaluation. The National Center for Mental Health diagnosed him with schizophrenia, and after over two years of confinement and treatment, he was declared fit to stand trial. A reverse trial was then conducted on his defense of insanity.
At trial, evidence showed the killing arose from a quarrel where the accused, jealous, stabbed his wife in front of their children. His mother-in-law testified she observed no prior abnormal behavior. The accused claimed no memory of the incident. A resident doctor from NCMH testified that schizophrenia involves impaired reasoning and judgment, making a person potentially incapable of distinguishing right from wrong. He opined it was highly possible the accused was already suffering from the illness prior to the crime but also noted that schizophrenics can have lucid intervals.

ISSUE

Whether or not accused-appellant Fernando Madarang is exempt from criminal liability by reason of insanity at the time of the commission of the crime.

RULING

No. The Supreme Court affirmed the conviction, holding that the defense of insanity was not sufficiently proven. The Court reiterated the legal principle that insanity, to be an exempting circumstance under Article 12 of the Revised Penal Code, must completely deprive the accused of intelligence or freedom of will at the very moment of the crime’s commission. The burden of proof rests on the accused, who must present clear and convincing evidence of such complete deprivation.
The Court found that the medical testimony, while establishing a history of schizophrenia, was inconclusive on the accused’s precise mental state during the stabbing. The doctor’s opinion that it was “highly possible” the illness existed beforehand was deemed insufficient, especially when coupled with the admission that schizophrenics experience lucid intervals. This created reasonable doubt about whether the accused completely lost his reason at the exact time of the act. The testimony of the mother-in-law, who noticed nothing peculiar in his behavior prior to the incident, further weakened the defense. The killing itself, arising from a jealous rage during a quarrel, suggested a motive rather than an act of an utterly demented mind. Consequently, the presumption of sanity prevailed.