G.R. No. 87084. June 27, 1990.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUANITO Q. AQUINO, accused-appellant.

FACTS

Accused-appellant Juanito Q. Aquino was charged with rape with homicide for the February 13, 1987 attack on Carmelita Morado. The victim, before succumbing to her injuries, gave a detailed ante-mortem statement to police officer Armando Frias, identifying Aquino as her assailant who raped and struck her with a stone. Medical examination confirmed severe injuries, including a skull fracture and lacerations consistent with the assault. Aquino was arrested that same evening at a public dance. Following his arrest, he was assisted by counsel during custodial investigation, where he gave a statement later ratified before a judge. Before arraignment, his counsel moved for his commitment to the National Center for Mental Health, citing unstable behavior. He was examined and diagnosed with “organic mental disorder with psychosis.”
At trial, the defense of insanity was interposed. Psychiatrist Dr. Nicanor Echavez testified that, in his opinion, Aquino was totally deprived of reason at the time of the crime. The defense also presented family testimony regarding Aquino’s alleged long history of mental illness. The prosecution, however, presented evidence of Aquino’s coherent and rational behavior before, during, and after the crime’s commission.

ISSUE

Whether or not the accused-appellant is exempt from criminal liability by reason of insanity.

RULING

The Supreme Court affirmed the conviction, rejecting the defense of insanity. The legal logic hinges on the presumption of sanity and the heavy burden of proof placed upon the accused claiming the exempting circumstance. The Court reiterated the doctrine that insanity must be proven to have completely deprived the accused of intelligence, freedom of will, or the power to discern at the very moment the crime was committed. Mere abnormality of the mind or a prior history of mental illness is insufficient; the crucial point is the condition of the mind at the instant of the criminal act.
The Court found the defense evidence insufficient to overcome the presumption of sanity. It gave greater weight to the prosecution’s evidence demonstrating Aquino’s conscious and deliberate actions surrounding the crime. His ability to flee the scene, attend a public dance, and later give a coherent and detailed extrajudicial confession—wherein he admitted the acts but claimed they were consensual and the killing accidental—showed a mind capable of reasoning, recollection, and fabrication of an exculpatory story. These acts were inconsistent with a total deprivation of intelligence or discernment. The psychiatric opinion, while noting a disorder, was not conclusively anchored on Aquino’s precise mental state on the night of the crime. The penalty was modified to reclusion perpetua from life imprisonment, and civil indemnity was set at P30,000.00.