G.R. No. 214444, November 17, 2020
People of the Philippines, Plaintiff-Appellee, vs. Lito Paña y Inandan, Accused-Appellant.

FACTS

Accused-appellant Lito Paña was charged with murder for hacking to death his cousin, Sherwin Macatangay, while the latter was sleeping. The prosecution established that the crime was witnessed by Aldwin Andal, who saw Paña committing the act. Paña was apprehended near the crime scene holding a bolo. At trial, Paña interposed the defense of insanity. He testified, corroborated by his mother Soledad, that he had been mentally ill since 2003, suffering from depression, sleepless nights, and suicide attempts, and had no recollection of the incident. They claimed financial constraints prevented professional medical consultation.
The Regional Trial Court convicted Paña of murder and sentenced him to reclusion perpetua, finding the defense’s evidence insufficient to prove insanity. The Court of Appeals affirmed the conviction. Paña appealed to the Supreme Court, arguing that expert testimony is not indispensable to prove insanity and that his mother’s testimony on his day-to-day behavior should suffice.

ISSUE

Whether the Court of Appeals erred in affirming Paña’s conviction by failing to appreciate his defense of insanity.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court clarified the guidelines for the insanity defense, abandoning the archaic “complete deprivation of intelligence” standard. It adopted a modern three-way test: (1) insanity must be present at the time of the crime; (2) insanity as the primary cause of the act must be medically proven; and (3) the insanity must cause an inability to appreciate the nature, quality, or wrongfulness of the act.
Applying this test, the Court found Paña’s defense insufficient. While expert testimony is not always indispensable, the totality of non-expert evidence must be compelling. Here, the testimonies of Paña and his mother were deemed self-serving, uncorroborated, and lacking in detail about his specific mental state on the day of the crime. Their claim of prior mental issues did not conclusively prove he was insane at the precise moment of the hacking. The Court noted the crime was committed with purpose—Paña targeted a sleeping victim, fled, and hid—indicating an awareness of wrongfulness. The defense failed to meet the burden of proving insanity by clear and convincing evidence. Thus, the presumption of sanity and the findings of fact by the lower courts stand.