GR 33211; (June, 1981) (Digest)
G.R. No. L-33211. June 29, 1981.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERNESTO PUNO y FILOMENO, accused.
FACTS
On September 8, 1970, Ernesto Puno entered the house of 72-year-old widow Francisca Col in Malabon, Rizal. Upon seeing her, he accused her of being a witch (“mangkukulam”), then repeatedly slapped and struck her head with a hammer, causing her death. The assault was witnessed by two tenants, Hilaria de la Cruz and Lina Pajes, who noted Puno’s reddish eyes and menacing look. After the killing, Puno threatened the witnesses not to report to the police and then fled. His father later surrendered him to authorities. Puno was charged with murder, with the information alleging aggravating circumstances.
At trial, the defense interposed the exempting circumstance of insanity. Evidence showed Puno had a long history of mental illness, diagnosed with “schizophrenic reaction,” and was an out-patient at the National Mental Hospital. Witnesses, including his wife, testified to his bizarre behavior before the incident, such as complaining of non-existent bees and brutally boxing his dog. Defense psychiatrists testified that Puno suffered from delusions, believing in witches and that harming them was necessary for self-cure.
ISSUE
Whether or not Ernesto Puno was insane at the time of the commission of the crime, thereby exempting him from criminal liability.
RULING
Yes, the Supreme Court acquitted Puno on the ground of insanity. The Court emphasized that the crucial point for determining criminal liability is the accused’s mental condition at the very moment the crime was committed. While the prosecution’s experts opined that Puno could generally function in society, the defense psychiatrists established that it was possible he was suffering from an onset of his schizophrenic reaction at the time of the killing. The Court gave weight to the medical history spanning eight years and the immediate bizarre prelude to the crime. It found that Puno acted under a specific delusion—that the victim was a “mangkukulam” harming him—and he killed her as a perceived act of self-defense against this phantom threat. His actions were a direct consequence of this psychotic delusion, not a product of a rational mind. The Court ruled that Puno, due to his mental disease, lacked the requisite discernment and freedom of will, thus falling under the exempting circumstance of insanity under the Revised Penal Code. The decision was reversed and Puno was ordered acquitted and confined in a mental hospital.