Case Digest by Clarisse Andrea C. Ong
FACTS: Petitioner Mare Claire Ruiz was charged with Homicide for killing Paulita Bonifacio in Mandaluyong City. During the preliminary conference, the defense admitted the killing but claimed Ruiz was legally insane. The prosecution denied this. A reverse trial ensued. The defense presented five witnesses, including psychiatrists to support their claim of insanity. Petitioner claimed that they were engaged in daily religious practices, including prayer and fasting. Petitioner claimed to have developed healing abilities and experienced visions, including seeing devils and apparitions. They performed “deliverance of demons.” Ruiz believed the victim transformed into a demon, and during a struggle, petitioner fatally injured her. Petitioner’s father found her on top of the victim, chanting. Medical professionals diagnosed Ruiz with psychotic disorders, potentially due to dehydration and malnutrition, and schizophrenia. She received treatment at multiple hospitals and the NCMH.
ISSUE: Whether petitioner is exempt from criminal responsibility as defined under Article 12(1) of the RPC.
RULING: The Supreme Court ruled in the AFFIRMATIVE. The Court found that the petitioner presented evidence of diminished intelligence and that her psychiatric condition directly caused the crime. To guide the bench, the court in People v. Pana made the three-part test to determine if the defense of legal insanity 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;
- Third, the effect of the insanity is the inability to appreciate the nature and quality of wrongfulness of the act.
Applying this test to the present case, the court determined that the petitioner was insane at the time of the crime, that the insanity was medically proven, and that it prevented her from understanding the nature or wrongfulness of her actions.
To appreciate legal insanity, our jurisdiction requires deprivation of intelligence, where intelligence is understood as the capability to discern right from wrong and comprehend the consequences of oneโs actions. As elaborated in People v. Haloc, mere abnormality of mental faculties will not exclude imputability. The accused must be so insane as to be incapable of entertaining a criminal intent, deprived of reason, and must be shown to act without the least discernment because there is a complete absence of the power to discern or a total deprivation of freedom of will.
NOTE: The argument that a lack of prior psychiatric records weakens a defense of legal insanity is flawed and discriminatory. The court highlighted that such records are not a prerequisite for proving insanity at the time of the crime, as required by the Panatest. While prior records can assist in demonstrating the medical basis of the insanity, their absence does not negate the defense’s burden to prove diminished intelligence during the offense. To insist on prior records would unjustly disadvantage those without access to healthcare, particularly the impoverished, who may neglect their mental health due to pressing survival needs.
THE BARRISTER 