G.R. No. and Date: G.R. Nos. L-9471 and L-9472, March 13, 1914

FACTS:
The appellant, Evaristo Vaquilar, was charged in two separate informations with the crime of parricide for killing his wife and his daughter. He was convicted in both cases and sentenced to life imprisonment, indemnification of the heirs, accessory penalties, and costs. The commission of the killings with a bolo was not denied. The defense did not present the appellant’s testimony but instead presented witnesses who testified that the appellant appeared insane at and after the crime. These witnesses stated that prior to the killings, the appellant had complained of pains in his head and stomach. At the scene, witnesses described him as having “very big and red” eyes and a “penetrating” sight, acting like a “madman” or “crazy” because he attacked his family and others randomly. A fellow jail inmate also testified that the appellant sometimes acted strangely in prison, crying out at night. The prosecution’s evidence included the gruesome nature of the victims’ wounds.

ISSUE:
Whether or not the appellant was insane at the time of the commission of the crimes, thereby exempting him from criminal liability.

RULING:
No. The Supreme Court affirmed the judgment of conviction. The Court held that the defense failed to prove that the appellant was legally insane at the time he killed his wife and daughter. The witnesses’ use of words like “crazy” or “madman” described a person in a frenzy of anger or passion, not a person with an unsound mind as defined by law. The Court distinguished between temporary passion or anger, which does not exempt one from criminal responsibility, and legal insanity resulting from a disease of the mind. The appellant’s violent and reckless actions during the attack and his subsequent conduct in jail were consistent with the remorse and extreme emotional state of a sane person who had committed grave crimes, not with insanity. The presumption of sanity stands unless overcome by affirmative proof, which was not satisfactorily presented in this case. Therefore, the appellant was criminally liable for the parricides.