People of the Philippines vs Jesus Domingo

G.R. No. 184343 – 599 Phil. 589 – Criminal Law – Exempting Circumstances – Insanity – Schizophrenia; Must be proven to exist at the time of the crime

In March 2000, Jesus Domingo had a check-up because he was suffering sleepless nights and would often hear voices telling him to kill. Nine days later, he entered a house armed with a knife and a screw driver. He stabbed to death two occupants and almost killed four others. One of the occupants pleaded to him to spare the children to which he responded: “Ngayon pa, nagawa ko na.” He was later indicted for two murders, one frustrated murder, two attempted murders, and one attempted homicide.

During trial, he underwent medical examination and he was found to be suffering from schizophrenia.

He was convicted by the trial court.

ISSUE: Whether or not the convictions are proper.

HELD: Yes. It is the defense’s duty to prove that insanity existed at the time of the crime. Here, the medical doctor testified that the schizophrenia of the accused only pertains to his mental status at the time of the examination; that he cannot tell for sure as to when accused’s schizophrenia started. On the other hand, the eyewitness testimony as to Domingo’s response to her plea to spare the children was a positive sign that he was aware of what he was doing, and that his reasoning faculties were unimpaired.

The law presumes every individual to be of sound mind; that all acts are voluntary, and that it is improper to presume that acts are done unconsciously. A person accused of a crime who pleads the exempting circumstance of insanity has the burden of proving beyond reasonable doubt that he or she was insane immediately before or at the moment the crime was committed.

Insanity exists when there is a complete deprivation of intelligence while committing the act; i.e., when the accused is deprived of reason, he acts without the least discernment because there is a complete absence of power to discern, or there is total deprivation of freedom of the will. Mere abnormality of the mental faculties is not enough, especially if the offender has not lost consciousness of his acts. Insanity is evinced by a deranged and perverted condition of the mental faculties and is manifested in language and conduct. An insane person has no full and clear understanding of the nature and consequences of his or her acts.

Read full text.