PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROSALINO DUNGO, accused-appellant.
G.R. No. 89420 - July 31, 1991
The Solicitor General for plaintiff-appellee.
Public Attorney's Office for accused-appellant.
Facts:
On March 16, 1987, a male person, identified as RosalinoDungo, went to the place where Mrs.Siguawas holding office at the Department of Agrarian Reform, Apalit, Pampanga. After a brief talk, the accused drew a knife from the envelope he was carrying and stabbed Mrs.Sigua several times. Accomplishing the morbid act, he went down the staircase and out of the DAR's office with blood stained clothes, carrying along a bloodied bladed weapon.
The accused, in defense of himself, tried to show in court that he was insane at the time of the commission of the offense. On January 20, 1989, the trial court found the accused guilty beyond reasonable doubt as principal for the crime of murder.
Issue:
Whether or no the accused is exempted from criminal liability due to insanity?
Held:
No. Under our jurisdiction, there has been no case that lays down a definite test or criterion for insanity. However, We can apply as test or criterion the definition of insanity under Section 1039 of the Revised Administrative Code, which states that insanity is "a manifestation in language or conduct, of disease or defect of the brain, or a more or less permanently diseased or disordered condition of the mentality, functional or organic, and characterized by perversion, inhibition, or by disordered function of the sensory or of the intellective faculties, or by impaired or disordered volition." An insane person has no full and clear understanding of the nature and consequence of his act. Insanity in law exists when there is a complete deprivation of intelligence. In the case at bar, it is an undisputed fact that a month or few weeks prior to the commission of the crime charged the accused confronted the husband of the victim concerning the actuations of the latter. He complained against the various requirements being asked by the DAR office, particularly against the victim. It is not usual for an insane person to confront a specified person who may have wronged him. Be it noted that the accused was supposed to be suffering from impairment of the memory, We infer from this confrontation that the accused was aware of his acts. This event proves that the accused was not insane or if insane, his insanity admitted of lucid intervals. Also, as stated by the trial court: “After the accused ran away from the scene of the incident after he stabbed the victim several times, he was apprehended and arrested in Metro Manila, an indication that he took flight in order to evade arrest. This to the mind of the Court is another indicia that he was conscious and knew the consequences of his acts in stabbing the victim”.