SC: No need for illness history to claim insanity as legal defense
INQUIRER FILE PHOTO
MANILA, Philippines — There is no need for a detailed history of mental illness to claim insanity as a legal defense.
This Supreme Court ruling is contained in a decision issued by its third division as it ordered the confinement of an accused of homicide at the National Center for Mental Health (NCMH) for treatment.
The accused was charged with homicide after her father found her naked, covered in blood, and chanting religious phrases over her best friend’s dead body.
She said she attacked her best friend after seeing her grow horns and transform into a demon. The accused also mentioned hearing the Virgin Mary’s voice telling her to place a cross into the victim’s heart.
Article 12 of the Revised Penal Code provides that a person who committed a crime and was found to be legally insane is exempt from criminal liability because there is no way for them to understand that their acts are wrong.
However, the Regional Trial Court and the Court of Appeals rejected the insanity plea, saying her mental state was not evaluated before, during, and after the crime was committed. Both courts said the evaluation is necessary to determine whether she knows her actions.
In reversing the rulings, the Supreme Court, through Associate Justice Alfredo Benjamin Caguioa, said a documented history of a psychiatric condition should never be an element to prove legal insanity.
“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 before 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,” the SC said.
The SC also acknowledged the unfair burden on impoverished individuals who may not have access to psychiatric care, stressing that the defense of legal insanity should be equally available to all.
It said requiring prior medical records “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.”
“Prison is no place for an individual afflicted with a mental disorder. Moreso, it is no place for one who committed a crime because of such mental illness,” the SC said.
“Incarceration will serve no practicable purpose and will, most definitely, worsen the person’s medical condition while behind bars,” it added.
In this case, the SC reversed and set aside the lower court’s ruling and acquitted the accused on the ground of legal insanity.
It also ordered the accused’s confinement at the NCMH for treatment and shall be released by the RTC upon recommendation of her attending physician.
