G.R. No. 244692, October 09, 2024
MARE CLAIRE RUIZ Y SERRANO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Mare Claire Ruiz y Serrano was charged with Homicide for the killing of Paulita Bonifacio y Sumintac on June 13, 2005, in Mandaluyong City. During the preliminary conference, the defense admitted the killing but interposed the exempting circumstance of legal insanity, leading to a reverse trial. The defense presented evidence that petitioner, a nurse, and the victim were close friends who engaged in intense religious activities, including fasting, prayer, and “deliverance” rituals. In the days leading to the incident, petitioner experienced hallucinations, seeing devils and apparitions, and perceived the victim transforming into a demon or Christ. On June 13, 2005, during a ritual, petitioner, believing she was fighting a demon, pounded the victim’s head on the floor, kicked her chest, and placed her hand inside the victim’s mouth. The landlady and housemates found the victim’s lifeless body, with petitioner on top, naked and chanting. Petitioner’s father witnessed her in this state, with glaring eyes, and had to handcuff her. Petitioner was brought to a hospital, where she was diagnosed with “Psychotic Disorder due to a Medical Condition” (hyponatremia, dehydration, malnutrition) by Dr. Portia R. Valles-Luspo and later with “Schizophrenia, Paranoid type” by Dr. Norma Macalalad-Lazaro of the National Center for Mental Health, who concluded she was insane before, during, and after the crime. The prosecution presented witnesses, including a medico-legal officer and a friend of the victim, but did not rebut the insanity defense with its own psychiatric evidence. The Regional Trial Court convicted petitioner of Homicide, which the Court of Appeals affirmed, giving more weight to the prosecution’s medico-legal findings over the defense’s psychiatric evidence.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for Homicide by failing to appreciate the exempting circumstance of insanity.

RULING

Yes. The Supreme Court granted the petition and acquitted petitioner on the ground of insanity. The Court held that the defense successfully proved petitioner’s complete deprivation of intelligence and freedom of will at the time of the killing, constituting the exempting circumstance under Article 12(1) of the Revised Penal Code. The defense presented clear, consistent, and unrebutted psychiatric testimony from two experts, Dr. Luspo and Dr. Lazaro, detailing petitioner’s psychotic state, hallucinations, and the medical causes (fasting, dehydration, malnutrition) leading to her insanity. The prosecution failed to present any contrary psychiatric evidence, relying only on the physical circumstances of the crime, which were insufficient to disprove insanity. The Court emphasized that insanity, as an exempting circumstance, must be proven by preponderance of evidence, not beyond reasonable doubt, and the defense met this burden. The Court found the CA erred in giving undue weight to the medico-legal report over the psychiatric evaluations. Consequently, petitioner is exempt from criminal liability. However, following Article 101 of the Revised Penal Code, she is civilly liable for the victim’s death, with such liability to be enforced against her property, except property exempt from execution.