G.R. No. L-52688. October 17, 1980.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. HONORATO AMBAL, accused-appellant.

FACTS

Honorato Ambal was convicted of parricide for killing his wife, Felicula Vicente-Ambal. On January 20, 1977, the victim was found near their home with multiple incised wounds, leading to her death shortly after. Immediately following the incident, Ambal entrusted his child to a neighbor, confessed to the barangay captain’s spouse that he had killed his wife, then proceeded to the municipal hall to surrender to a policeman, reiterating his confession. His blood-stained clothing and a bolo with a broken tip were recovered. The killing culminated from a fifteen-year marriage marred by frequent quarrels, exacerbated by the wife’s occasional absences from the conjugal home. The immediate provocation was an argument where Felicula, after failing to buy medicine for Ambal who had influenza, told him it would be better if he were dead.
At his arraignment, Ambal pleaded not guilty. After the prosecution presented its case, his counsel de oficio raised the defense of insanity. The trial court ordered a mental examination. Dr. Maximino R. Balbas, Jr., who observed Ambal, diagnosed him as having a “passive-aggressive, emotionally unstable, explosive or inadequate personality” but testified that Ambal was normal before and after the crime, though he experienced “Psychosis due to short frustration tolerance” during the commission. Another physician, Dr. Cresogono Llacuna, who had treated Ambal previously, concluded he suffered from psychoneurosis, a nervous disturbance not amounting to insanity, and affirmed Ambal was not insane.

ISSUE

Whether the accused, Honorato Ambal, was insane at the time of the commission of the crime, thereby exempting him from criminal liability under Article 12 of the Revised Penal Code.

RULING

The Supreme Court affirmed the conviction, holding that Ambal failed to prove he was legally insane at the time of the killing. The legal presumption is that every person is of sound mind, and the burden to rebut this with clear and convincing evidence lies with the accused claiming insanity. The Court emphasized the crucial distinction between legal insanity, which exempts from liability, and mere passion, emotional instability, eccentricity, or a psychoneurotic condition, which do not.
The medical testimony established that Ambal was normal before and after the crime. Dr. Balbas’s finding of a temporary “psychosis” during the act was interpreted not as legal insanity but as an explosive reaction to severe provocation—his wife’s hurtful remark—within a dysfunctional marital history. His actions immediately after the crime, including his coherent confession, deliberate surrender, and normal behavior in jail (performing chores and running errands), demonstrated he was fully aware of the wrongfulness of his act and its consequences. Therefore, he did not act during a state of complete deprivation of intelligence or will. The Court found the mitigating circumstance of voluntary surrender present. Consequently, for the crime of parricide under Article 246 of the Revised Penal Code, with one mitigating circumstance and no aggravating circumstances, the penalty of reclusion perpetua was correctly imposed. The trial court’s decision was affirmed.