GR 89420; (July, 1991) (Digest)
G.R. No. 89420 ; July 31, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROSALINO DUNGO, accused-appellant.
FACTS
The accused-appellant, Rosalino Dungo, was charged with the murder of Belen Macalino Sigua, an employee of the Department of Agrarian Reform in Apalit, Pampanga. The prosecution established that on March 16, 1987, Dungo went to the victim’s office, engaged her in a brief conversation, and then stabbed her multiple times with a knife concealed in an envelope, resulting in her death. Witnesses identified Dungo, who fled the scene but was later apprehended. The victim’s husband testified about a prior encounter where Dungo expressed frustration over the victim’s official actions.
In his defense, Dungo pleaded insanity. His wife and a neighbor testified to his erratic behavior prior to the incident, including delusions. He claimed unawareness of the stabbing. Expert witnesses from the National Center for Mental Health diagnosed him with organic mental disorder secondary to a stroke, concluding he was psychotic before, during, and after the crime. The prosecution presented rebuttal witnesses, including his treating physician, who stated his illness did not impair his intelligence.
ISSUE
Whether the accused-appellant successfully proved the defense of insanity to exempt him from criminal liability.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the presumption of sanity under Philippine law. The burden of proving insanity, an affirmative defense, lies with the accused and must be established beyond reasonable doubt. The Court found that the defense failed to meet this stringent quantum of proof. While defense experts opined on Dungo’s psychosis, their conclusion was contradicted by other evidence indicating conscious, deliberate action. The trial court correctly noted that Dungo concealed the weapon, executed a sudden attack constituting treachery, and fled to evade arrest—acts demonstrating awareness of the crime’s nature and consequences. The Court deferred to the trial court’s firsthand assessment of witness credibility. Doubt regarding the fact of insanity is resolved in favor of sanity to prevent sane individuals from escaping punishment. Thus, the presumption of sanity stands unrebutted, and Dungo is criminally liable for murder.