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AT A GLANCE:
In Ruiz v. People of the Philippines (G.R. No. 244692), the Supreme Court held that while prior medical records can be relevant, they are not required to prove that the accused’s medical condition led to the crime. Therefore, the absence of documented psychiatric history should not be taken against the accused claiming legal insanity.
In the recent case of Mare Claire Ruiz v. People of the Philippines (G.R. No. 244692, October 9, 2024), the Supreme Court revisited the exempting circumstance of insanity under Article 12 of the Revised Penal Code (RPC).
Under Article 12 of the RPC an imbecile or an insane person is exempt from criminal liability, unless the latter has acted during a lucid interval.
In acquitting Ruiz due to insanity, the Supreme Court used the three-way test it crafted in the case of People of the Philippines v. Lito Paña to determine whether the defense is meritorious: first, insanity must be present at the time of the commission of the crime; second, insanity, which is the primary cause of the criminal act, must be medically proven; and third, the effect of the insanity is the inability to appreciate the nature and quality or wrongfulness of the act.
In several cases, the Court ruled on insanity cases by determining if the accused were aware of the wrongfulness of their acts. Paña named a few such as, immediate surrender to the authorities, escaping arrest, display of remorse, and threatening the victim to avoid getting caught, which have been appreciated as proof that the accused understood the nature and consequence of the acts committed.
Beyond doubt, insanity refers to an individual’s state of mind. It goes without saying, however, that an individual’s thoughts are proven only through overt acts. Courts, therefore, can only consider evidence relating to the behavioral patters of the accused to determine whether they are legally insane.
The Philippines has adopted a requirement of deprivation of intelligence. Intelligence is commonly understood as the capability to discern right from wrong and comprehend the consequences of one’s actions. Hence, any act, demeanor, or reaction which demonstrates this immediately before, during, or after committing the crime lends support to a finding of insanity thru the first and third tests of Paña.
In this case, the Court acknowledged the difficulty of having to prove that an accused was deprived of intelligence at the exact moment of the commission of the crime. Thus, it held that insanity may be proven through an accused’s demeanor or actions either immediately before or immediately after the commission of the crime.
As long as an accused could proffer, thru clear and convincing evidence, proof of deprivation of intelligence either immediately before, during, or immediately after the commission of the crime, it shall be sufficient to meet the first test of Paña.
It goes without saying that proof of deprivation of intelligence thru the accused’s demeanor or overt acts immediately before or immediately after the commission of the crime is already tantamount to proof of deprivation of intelligence at the precise moment of commission.
With regard to the second test, the Supreme Court held that legal insanity, as an exempting circumstance, must be medically shown, unless there are extraordinary circumstances and there is no other evidence available.
While our procedural rules allow ordinary witnesses to testify on the “mental sanity of a person with whom he [or she] is sufficiently acquainted,” the testimony and reports of physicians have greater evidentiary value in understanding an accused’s mental state. The nature and degree of an accused’s mental illness can be best identified by medical experts equipped with specialized knowledge to diagnose a person’s mental health.
Without a doubt, it is highly crucial for the defense to present an expert who can testify on the mental state of the accused. While testimonies from medical experts are not absolutely indispensable in insanity defense cases, their observation of the accused are more accurate and authoritative. Expert testimonies enable courts to verify if the behavior of the accused indeed resulted from a mental disease.
The Supreme Court emphasized that the lack of prior psychiatric records should not be taken against one who pleads the defense of legal insanity.
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.
To settle this, the Court noted that 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.
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