“It was medically proven by the examining psychiatrists that XXX was suffering from schizophrenia at the time of the commission of the crime”
“Schizophrenia has been described as a chronic mental disorder characterized by inability to distinguish between fantasy and reality, and often accompanied by hallucinations and delusions. It is a medical condition which deprives a person of discernment.” (People v. XXX, G.R. 273354, Oct. 29, 2025)
The Supreme Court explained in the case of People v. XXX that, “at the time of the incident, XXX’s mental state deprived her of the ability to appreciate the nature and wrongfulness of her act. Thus, she is exempt from criminal liability under Article 12(1) of the Revised Penal Code.” (Op cit.)
Jurisprudence has defined insanity as “‘a manifestation in language or conduct of disease or defect of the brain,… functional or organic, and characterized by perversion, inhibition, or disordered function of the sensory or of the intellective faculties, or by impaired or disordered volition.’” (Op cit.)
“[T]he law presumes all persons to be of sound mind, insanity is the exception rather than the general rule. In claiming insanity, an accused admits the commission of the criminal act but seeks exemption from criminal liability due to lack of voluntariness or intelligence.” (Op cit.)
“Thus, it is incumbent upon the accused to prove insanity by clear and convincing evidence. Considering that insanity refers to an individual’s state of mind, it can only be proven through overt acts. Courts, therefore, can only consider evidence relating to the behavioral patterns of the accused to determine whether they are legally insane.” (Op cit.)
“Since 1950, the Court’s ruling in People v. Formigones had remained relatively undisturbed. It held that insanity as an exempting circumstance should be ‘deprived completely of reason or discernment and freedom of the will at the time of committing the crime.’” (Op cit.)
“The Formigones doctrine was further expounded in People v. Rafanan, Jr. resulting in the formulation of two distinguishable tests (a) the test of cognition [which requires] ‘complete deprivation of intelligence in committing the [criminal] act, ’and (b) the test of volition [which requires] ‘a total deprivation of freedom of the will.’” (Op cit.)
However, in People v. Pana, the Supreme Court set forth new standards in establishing insanity as an exempting circumstance through the three-way test: “first, insanity must be present at the time of the commission of the crime; second, insanity,… 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.” (Op cit.)
In the case of People v. XXX, on January 9, 2010 at around 8:30 a.m., Gaviola, who was scavenging at the side of Pasig River, saw XXX allowing her daughter to stand with her at the side of the bridge. Thereafter, Gaviola saw XXX, while embracing her daughter, jumped into the river.
“At the time, Moreno was scavenging along Pasig River, near the area of Fort Santiago, on board his styrofoam banca… [He] heard people shouting from the top of Delpan Bridge asking for help.” Seeing XXX drowning, Moreno went to save her and brought her to the “pantalan.”
The following day, Moreno heard people shouting near his house that a child was found in the river. He saw the lifeless body of the child, who turned out to be XXX’s daughter. In her defense, “XXX denied that she killed her daughter and that she was not herself at the time of the incident.”
“XXX testified that she remembered walking with her daughter but that she could not remember anything after. XXX claimed that she only regained consciousness when she was already floating in the water…, [and] she only found out that her daughter was dead when she was informed of it by her live-in partner…”
“The defense presented Dr. Bravo from the NCMH, who testified that they were directed by the RTC to conduct an examination of accused XXX to determine if she was fit to stand trial.” “Dr. Bravo narrated that, based on the patient’s history,… XXX was found to be suffering from ‘schizophrenia’… [but] was competent to stand the rigors of court trial.” (Op cit.)
After carefully combing through the records and the submission of the parties, and after applying the standards established in Paña, the Supreme Court found XXX exempt from criminal liability. It was medically proven by the examining psychiatrists that XXX was suffering from schizophrenia at the time of the commission of the crime.
Finally, the Supreme Court was “convinced that at the time of the incident, XXX’s mental state deprived her of the ability to appreciate the nature and wrongfulness of her act. Thus, she is exempt from criminal liability under Article 12(1) of the Revised Penal Code.”
