UP Law F2021 People v Dungol

Medical Jurisprudence 1991 PARAS, J.

FACTS

 On March 16, 1987 Rosalino Dungo murdered Belen Macalino Sigua at Mrs. Sigua’s
office at the Department of Agrarian Reform, Apalit, Pampanga between 2:00 – 3:00
in the afternoon.

 After a brief talk, the accused drew a knife from the envelope he was carrying and
stabbed Mrs. Sigua several times. After which he departed from the office with blood
stained clothes, carrying a bloodied bladed weapon.

 Rodolfo Sigua, husband of the deceased, testified that Rosalino Dungo inquired from
him why his wife was requiring so many documents from him. Rodolfo explained to
him the procedure at the DAR.

 In his defense, the accused’s wife tried show that he was insane at the time of the
commission of the act:
- Two weeks prior to March 16, 1987, Andrea (Rosalino’s wife) noticed
that he (Rosalino) appears to be in deep thought always, maltreating their
children when he was not used to it before. There were also times that
her husband would inform her that his feet and head were on fire when in
truth they were not.
- On that fateful day, Rosalino complained of stomachache but they didn't
bother to buy medicine as the pain went away immediately. Thereafter,
he went back to the store. But when Andrea followed him to the store, he
was no longer there. Worried, she looked for him. On her way home, she
heard people saying that a stabbing occurred. She saw her husband in her
parents-in-law's house with people milling around. She asked her
husband why he did the act, to which Rosalino answered, "That's the only
cure for my ailment. I have cancer of the heart. If I don't kill the deceased
in a number of days, I would die. That same day, the accused went to
Manila.

 Also, the defense’s counsel presented two resident psychiatrists from the National
Center for Mental Health to testify to the accused’s alleged insanity:

 Dr. Santiago and Dr. Echavez of the NCMH testified that the accused was confined in
the mental hospital, as per order of the trial court dated Aug. 17, 1987. Based on the
reports of their staff, they concluded that Rosalino was psychotic or insane long
before, during and after the commission of the alleged crime and classified his
 insanity as an organic mental disorder secondary to cerebro-vascular accident or
stroke.

 However, Dr. Balatbat (the attending Neuro MD) who treated the accused for
ailments secondary to stroke, and Dr. Lim who testified that the accused suffered
dorm occlusive disease, concluded that Rosalino was somehow rehabilitated after a
series of medical treatment in their clinic. (wow nice)

RATIO

W/N the accused was insane during the commission of the crime charged.
HELD: No. For insanity to relieve the person of criminal liability, it is necessary that there
be a complete deprivation of intelligence in committing the act, that he acts without the
least discernment and that there be complete absence or deprivation of the freedom of
the will.
It is difficult to distinguish sanity from insanity. There is no definite defined border
between sanity and insanity. Under foreign jurisdiction, there are three major criteria in
determining the existence of insanity, namely: delusion test, irresistible impulse test, and
the right and wrong test.

However, under Philippine jurisdiction, there's no definite test or criterion for insanity.
However, the definition of insanity under Sec 1039* of the Revised Administrative Code
can be applied. In essence, it states that insanity is evinced by a deranged and perverted
condition of the mental faculties, which is manifested in language or conduct. An insane
person has no full and clear understanding of the nature and consequence of his act.

Evidence of insanity must refer to the mental condition at the very time of doing the act.
However, it is also permissible to receive evidence of his mental condition for a
reasonable period before and after the time of the act in question. The vagaries of the
mind can only be known by outward acts.
It is not usual for an insane person to confront a specified person who may have wronged
him. But in the case at hand, the accused was able to accurately identify Mrs. Sigua. From
this, it can be inferred that the accused was aware of his acts. This also established that
the accused has lucid intervals.

Moreover, Dr. Echavez testified to the effect that the appellant could have been aware of
the nature of his act at the time he committed it when he shouted (during laboratory
examination) that he killed Mrs. Sigua. This statement makes it highly doubtful that the
accused was insane when he committed the act.

The fact that the accused was carrying an envelope where he hid the fatal weapon, that he
ran away from the scene of the incident after he stabbed the victim several times, that he
fled to Manila to evade arrest, indicate that he was conscious and knew the consequences
of his acts in stabbing the victim. (This was taken from the trial court's decision).

PUNISHMENT:
- To suffer the penalty of reclusion perpetua and the accessories of the law;

- To indemnify the family of the victim in the amount of P75,000.00 as actual

damage, P20,000.00 as exemplary damages and P30,000.00 as moral damages.

DEFENITIONS:
Compos Mentis (lit. having command of mind) — Refers to a person acting with a sound
mind and with full discretion, under exercise of his free will, and with complete
awareness and intelligence.

3 CRITERIA FOR DETERMINING INSANITY UNDER FOREIGN JURISPRUDENCE:

1) Insane delusion test– manifested by a false belief for which there is no reasonable
basis and which would be incredible under the given circumstances to the same
person if he is of compos mentis. Under the delusion test, an insane person believes
in a state of things, the existence of which no rational person would believe.
2) Irresistible impulse test – A person acts with irresistible impulse when, by reason
of duress or mental disease, he has lost the power to choose between right and
wrong, his free agency being, at the commission of the act, destroyed.
3) Right and Wrong test – In this test, a person is insane when he suffers from such
perverted condition of the mental and moral faculties as to render him incapable
of distinguishing between right and wrong.

PROVISIONS:
Article 1039, Revised Administrative Code
- “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.”

NOTES:
One who suffers from insanity at the time of the commission of the offense charged cannot,
in a legal sense, entertain a criminal intent and cannot be held criminally responsible for
his acts. His unlawful act is the product of a mental disease or a mental defect. However, in
the case at bar, it is without doubt that he had the intent and he knows who he is going to
kill. In order that insanity may relieve a person from criminal responsibility, it is necessary
that there be a complete deprivation of intelligence in committing the act, that is, that the
accused be deprived of cognition; that he acts without the least discernment; that there be
complete absence or deprivation of the freedom of the will.
Thus, insanity may be shown by surrounding circumstances fairly throwing light on the
subject, such as evidence of the alleged deranged person's general conduct and appearance,
his acts and conduct inconsistent with his previous character and habits, his irrational acts
and beliefs, and his improvident bargains.

FALLO
Affirmed w/o costs