G.R. No. L-51736 August 4, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO ARAGON, defendant-appellant.

FACTS

The prosecution established that on the evening of August 7, 1978, in General Santos City, Elsa Balena was walking home when accused Rolando Aragon approached her. He forcibly dragged her to a dark area of a plaza while choking her and threatening to kill her if she shouted. Despite her resistance, Aragon pushed her to the ground, removed her clothing, and had carnal knowledge against her will. Balena bit his lips during the struggle. After the act, Aragon fled. Balena immediately reported the incident to the police, describing her attacker. A medical examination confirmed fresh hymenal lacerations, the presence of sperm cells, and multiple injuries consistent with a violent struggle.
The following morning, Balena was brought to the police station where she immediately and positively identified Aragon as her assailant, noting the fresh injury on his lips from her bite. Aragon was at the station because he had been found acting suspiciously near the crime scene. At trial, the defense interposed the exempting circumstance of insanity, presenting a psychiatric report diagnosing Aragon with “Mental Deficiency,” “Personality Disorder,” and “Borderline Psychosis.”

ISSUE

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

RULING

The Supreme Court affirmed the conviction, holding that insanity was not sufficiently proven to exempt Aragon from liability. The Court reiterated the legal standard for insanity as an exempting circumstance, which requires proof of a complete deprivation of intelligence or a total absence of freedom of will at the time of the crime’s commission. Mere abnormality of mental faculties, mental deficiency, or personality disorders do not constitute legal insanity. The burden of proof rests on the party invoking the exemption, and it must be established by clear and positive evidence.
Applying this to the case, the psychiatric report on Aragon indicated he was cooperative, gave a fair account of events, was emotionally stable though slightly apprehensive, and was oriented to place. He denied hallucinations and delusions. The Court found that these observations did not demonstrate a complete deprivation of reason or discernment during the criminal act. His alleged mental conditions, while noted, fell short of the total deprivation required by law. Consequently, his feeble-mindedness did not absolve him of criminal responsibility for the crime of forcible abduction with rape. The appealed judgment was affirmed with a modification increasing the civil indemnity.