G.R. No. 95029 March 24, 1993
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ADOLFO NARVAS PASCUAL, accused-appellant.

FACTS

Accused-appellant Adolfo Pascual was charged with the rape of Virginia de Guzman on January 17, 1982. The prosecution evidence, as summarized by the trial court, established that Pascual had courted de Guzman and became her boyfriend. On the feast day of the Sto. Niño, he invited her to his aunt’s house in Tondo, Manila. After attending mass, they went to the house. Pascual then led de Guzman to an adjacent unoccupied old house for dinner. There, he suddenly kissed her and tried to remove her blouse. When she resisted and shouted, he pulled out a balisong, pointed it at her neck, and forced her to the ground floor. She tried to pound on the door for help, but his aunt’s inquiry was dismissed by Pascual. He boxed her, tried to stab her, and in the struggle, she injured her hands. He then dragged her back to the second floor, removed her clothes at knifepoint, and succeeded in having sexual intercourse with her five times over several hours, from around 7:00 PM until 2:00 AM the next day, threatening her with the knife throughout.
In his defense, Pascual pleaded insanity and denied the crime. He claimed no recollection of the events. Evidence showed he was first admitted to the National Center for Mental Health on May 7, 1980, diagnosed with “schizoprenia, undifferentiated type,” and was discharged on an overdue pass on January 5, 1982. On March 5, 1982, the trial court ordered his confinement for examination. He was certified fit to stand trial only on July 3, 1987. After trial, the Regional Trial Court found him guilty of rape and sentenced him to reclusion perpetua, ordered him to pay moral damages, and credited his preventive confinement.

ISSUE

The main issue is whether the accused-appellant was insane at the time of the commission of the rape, thereby exempting him from criminal liability under Article 12 of the Revised Penal Code.

RULING

The Supreme Court affirmed the conviction with modification. The Court ruled that the accused-appellant failed to prove his insanity defense. The law presumes every person to be sane, and the burden of proving insanity lies with the accused. The evidence, including the testimony of his own witness, Dr. Eduardo Maaba, showed that during examinations after the incident, the accused was responsive and coherent. His actions during the rape—such as assuring the victim he would take responsibility, threatening her with a knife to prevent noise, and his sequential, deliberate acts over several hours—demonstrated a conscious design and awareness of the wrongfulness of his acts. The Court found no evidence of a total deprivation of intelligence or freedom of will at the time of the crime. The defense of schizophrenia failed as it was not shown that the disease completely impaired his cognitive faculties. The trial court’s finding of guilt beyond reasonable doubt was upheld. The Court also increased the indemnity to the victim to P40,000.00 in line with prevailing jurisprudence.