The defense of insanity is an important legal argument in the criminal justice system. This defense is based on the idea that a person should not be held legally punished if he cannot understand what he is doing because of a defect of understanding such that there can be no free will of act. In People vs. Madarang (G.R. No. 132319, 12 Mat 2000) it was held:
“In all civilized nations, an act done by a person in a state of insanity cannot be punished as an offense. The insanity defense is rooted on the basic moral assumption of criminal law. Man is naturally endowed with the faculties of understanding and free will. The consent of the will is that which renders human actions laudable or culpable. Hence, where there is a defect of the understanding, there can be no free act of the will. An insane accused is not morally blameworthy and should not be legally punished. No purpose of criminal law is served by punishing an insane accused because by reason of his mental state, he would have no control over his behavior and cannot be deterred from similar behavior in the future.”
Thus, Article 12 of the Revised Penal Code exempts an insane person from criminal liability, to wit:
“Article 12. Circumstances which exempt from criminal liability. – The following are exempt from criminal liability:
1. An imbecile or an insane person, unless the latter has acted during a lucid interval.
When the imbecile or an insane person has committed an act which the law defines as a felony (delito), the court shall order his confinement in one of the hospitals or asylums established for persons thus afflicted, which he shall not be permitted to leave without first obtaining the permission of the same court. x x x”
In shaping how this defense is applied, several important Supreme Court rulings have come into play. These decisions clarify the standards for evaluating mental competency and further define the legal boundaries surrounding claims of insanity.
The insanity defense hinges on a critical question: Could the accused distinguish right from wrong at the time of the crime? This principle underscores the belief that moral culpability requires an understanding of one’s actions. Is it necessary to show proof of prior history of mental illness in order to effectively raise the defense of insanity?
The case of Ruiz vs. People (G.R. No. 244692, 09 October 2024) enunciated that it is not necessary to prove or show documented history of mental illness in order to claim insanity as a defense in a criminal case. In the said case, the accused experienced severe mental disturbances during the commission of the offense but did not have a documented history of mental illness. The Philippine Supreme Court recognized her defense and ruled:
“In support of petitioner’s conviction, it was mentioned that “the pieces of evidence proffered by the [d]efense failed to prove [petitioner’s] insanity at the time of the commission of the crime. If at all, these pieces of evidence were gathered after the commission of the crime.”
Furthermore, it was claimed that the examinations of Drs. Luspo and Lazaro were made only after petitioner had already killed the victim “when the only relevant inquiry in this case is whether [p]etitioner was insane at the very moment when the crime was committed.”
To the Court, it seems that one of the reasons why petitioner’s conviction was upheld is because she did not have any existing psychiatric records pointing to her mental state of being insane. Otherwise, it would be impossible and preposterous to expect that a doctor could examine a patient while in the height of committing a crime.
First, it should be stressed that having a documented history of a psychiatric condition is not, and should never be, an element required to prove legal insanity. In fact, it does not have any legal or evidentiary significance except to lend assistance in proving the second test under Paña, specifically, that the accused’s medical condition is the reason why the crime was committed.
Furthermore, prior psychiatric records could not establish insanity at the precise time of the commission of the crime because, for obvious reasons, medical reports from doctors prior to the commission of the crime cannot be considered as having been rendered immediately before the commission of the crime, unless the facts clearly establish so. Thus, the foregoing arguments are misplaced.
To settle this, prior medical records are only relevant, but not the only smoking gun, in proving the second test in Paña. On the other hand, lack thereof, absolutely has nil effect in the defense’s burden to prove a deprivation of intelligence at the time of the commission of the crime, or Paña’s first and third tests.
Second, and more importantly, if the Court were to subscribe to this argument, then it deliberately turns a blind eye to the unfortunate reality that health care is not accessible to majority of the population. In fact, the “Court realizes the difficulty and additional burden on the accused to seek psychiatric diagnosis.” The argument being posited baselessly puts the impoverished at a disadvantaged position, who, due to circumstances beyond their control, are forced to brush aside conditions of their health in order to prioritize the immediate need to put food on the table and other necessities. The plea of insanity, as like any other similar defense available under the law, should always be equally accessible to all regardless of background or status. Adding additional burdens and qualifications to avail them, when not necessary and decisive to the legal issue, is undeserving to be branded as dispensation of justice.
Therefore, not only is this type of argument baseless in law, but its application and effect are also highly discriminatory. This should never have any place in our legal system.”
Thus, the Supreme Court’s acceptance of the accused’s argument illustrates a broader recognition that the latter can successfully plead insanity based on her mental state at the time of the crime, rather than relying solely on historical evidence. In sum, the aforesaid case made the following points:
- No Prior Medical Records Required: A history of mental illness or documented psychiatric records is not necessary to claim legal insanity as a defense in a criminal case.
- Broad Evidence for Insanity: Courts can consider behavior and evidence of insanity before, during, or immediately after the crime. Legal insanity is established if the person was deprived of intelligence at any of these points.
- Support for Vulnerable Individuals: The decision emphasizes fairness for underprivileged individuals who might lack access to psychiatric care. It ensures that legal defenses, like insanity, are not restricted by socioeconomic status or medical history.
- Equal Access to Justice: The ruling stresses that adding unnecessary burdens, such as requiring prior medical evaluations, undermines justice. Everyone should have equal opportunity to present legal defenses.
- Confinement for Treatment: While the accused is exempt from imprisonment due to insanity, the court ordered confinement at a mental health facility for evaluation and treatment, with release contingent upon a physician’s recommendation and court approval.
- Civil Liability: Despite being exempted from criminal liability, the accused can still be civilly liable for damages.
Mental illness and imprisonment are incompatible, particularly for those whose crimes stem from psychiatric conditions. Jail time may prove futile and could inevitably aggravate the individual’s mental state during confinement. Upon release, there’s no guarantee of rehabilitation or successful societal reintegration without the risk of recurring violent conduct. After all, reformation and punishment are meaningless for those who acted under mental illness without proper medical care.
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