G.R. No. 188320 ; June 29, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. HONORIO TIBON y DEISO, Accused-Appellant.

FACTS

Accused-appellant Honorio Tibon was charged with two counts of parricide for the fatal stabbing of his two legitimate sons, aged three and two, on December 12, 1998. Tibon and the children’s mother, Gina Sumingit, lived together as common-law spouses. Gina had left to work abroad, and Tibon later learned she was having an affair. Subsequently, Tibon was observed drinking heavily and hitting the children. On the night of the incident, Tibon’s mother and siblings entered his room and discovered the two lifeless children with stab wounds. Upon being seen, Tibon stabbed himself and jumped from a window in an attempted suicide. The children were declared dead at the hospital.
At trial, the prosecution presented witnesses, including a police investigator who testified that Tibon, while under police guard in the hospital, voluntarily confessed to the killings after being informed of his rights. The medico-legal officer detailed the fatal nature of the children’s wounds, indicating extreme violence. Gina also testified that Tibon confessed and begged for forgiveness. Tibon, as the sole defense witness, claimed insanity, stating he had no memory of the events.

ISSUE

Whether the Court of Appeals correctly affirmed the trial court’s finding that the prosecution proved Tibon’s guilt for parricide beyond reasonable doubt, rejecting his defense of insanity.

RULING

The Supreme Court affirmed the conviction. The defense of insanity was correctly rejected. Jurisprudence requires that for insanity to exempt one from criminal liability, it must be shown that the accused was completely deprived of intelligence at the time of the act, meaning he did not know the nature and quality of his act or that it was wrong. Tibon failed to prove this complete deprivation. His actions before, during, and after the crime demonstrated awareness and control: he was seen hitting the children earlier, he killed them in the privacy of his room, and his immediate reaction upon discovery—attempting suicide and escape—evinced a conscious guilt and understanding of the wrongfulness of his acts. His claim of amnesia, unsupported by evidence, did not equate to legal insanity. The positive evidence, including his judicial confession and the credible testimonies of witnesses, established all elements of parricide under Article 246 of the Revised Penal Code: he killed his two legitimate children. The Court modified the awarded damages, ordering civil indemnity, actual damages, moral damages, and exemplary damages for each victim.