To the layperson, the meaning of insanity is that the person is simply crazy. But the law is more particular when it comes to this concept since insanity has legal implications if it is sufficiently shown or proven. In fact, in our Revised Penal Code, insanity exempts the accused from criminal liability. “Art. 12. Circumstances which exempt from criminal liability. The following are exempt from criminal liability: 1. An imbecile or an insane person, unless the latter has acted during a lucid interval.” Of course, being an imbecile is something permanent but for the insane, there may be lucid intervals and the commission of a crime during said interval does not exempt the person from criminal liability. In telenovelas or movies, the plea of insanity has become a favorite excuse to spice up the plot. It would then turn out that the accused was not really insane but made an elaborate scheme to act insane and even have doctors after being paid sums of money to certify that the person is insane. A good plot for audiences to get mad and hate the character but insanity can really be raised by the defense and can actually cause the dismissal of the case.
People vs. Bonoan
This is a very simple case wherein one day the accused Bonoan armed with a knife, attacked the victim Guison and stabbed him three times, was brought to the hospital but eventually died after three days. During arraignment, the defense objected alleging that the accused cannot stand trial because he is insane. After receiving reports and testimony on the condition of the accused, the court deferred the arraignment and ordered the accused committed to a mental institution. When he was well enough to stand trial, the accused was arraigned and tried but alleged that he was insane when he committed the crime. During the trial, the regional trial court found him guilty and was sentenced to reclusion perpetua. The accused appealed.
Insane
It must be noted that the case was decided in 1937 and there have been lots of changes in our jurisprudence since then. The Supreme Court eventually overturned the decision of the Regional Trial Court and pronounced the accused exempted from criminal liability because of his insanity. The Supreme Court in its decision stated that: “Direct testimony is not required, nor are specific acts of derangement essential (People v. Tripler, supra) to establish insanity as a defense. Mind can only be known by outward acts. Thereby, we read the thoughts, the motives and emotions of a person and come to determine whether these acts conform to the practice of people of sound mind. To prove insanity, therefore, circumstantial evidence, if clear and convincing, suffice.” (People vs. Bonoan, G.R. No. 45130. February 17, 1937) The Court even went on to pronounce and re-iterate that doctrine that: “when a defendant in a criminal case interposes the defense of mental incapacity, the burden of establishing that fact rests upon him”. In reversing the decision of the RTC, the SC pointed out that the lower court erred because it held that “the defendant was not insane at the time of the commission of the act for which he was prosecuted on the theory that the insanity was only occasional or intermittent and not permanent or continuous”. The Court turned to the findings of the doctors at the mental institution and even the actions of the arresting officers. The SC found the accused exempted from criminal liability but ordered him committed in a mental institution. The Court was narrowly split in this decision. Three justices disagreed with the four on the majority. They believe that the accused was sane when he committed the crime.
