Mental health records not mandatory for legal insanity claim—SC
The Supreme Court of the Philippines has determined that an individual does not require a documented history of mental illness to use legal insanity as a defense in court.
Following a decision written by Associate Justice Alfredo Benjamin S. Caguioa, the SC's Third Division, a female defendant in a homicide case was acquitted by reason of "insanity."
In a press release, SC outlined that the defendant faced a murder charge following an incident in which her father discovered her "naked, covered in blood, and reciting religious phrases over her best friend's lifeless body."
The defendant contended that she assaulted her friend after witnessing her transform—growing "horns" and becoming a "demon."
Additionally, she claimed to have "heard the voice of the Virgin Mary" instructing her to place a cross into the victim's heart, along with other directives.
The ruling
The Regional Trial Court (RTC) and the Court of Appeals (CA) both rendered a guilty verdict, dismissing the accused defense of insanity.
According to the RTC and CA, it was essential for her mental state to be thoroughly assessed before, during, and after the commission of the crime to establish whether a mental condition influenced her actions at the time.
However, the SC overturned this decision, saying that the defendant presented sufficient evidence of insanity when the crime occurred. It clarified that establishing legal insanity only necessitates evidence showing that the "accused was deprived of intelligence either before, during, or immediately" after committing the crime.
Thus, SC said that "the absence of documented psychiatric history should not be taken against the accused claiming legal insanity."
Under Article 12 of the Revised Penal Code, an individual who commits a crime and is proven legally insane is exempt from criminal liability "because they cannot understand the wrongfulness of their actions."
"The SC recognized the difficulty of proving insanity at the exact moment of the crime, so courts may consider the accused's behavior before or after the incident," it said.
The Supreme Court also recognized the unjust burden placed on economically disadvantaged individuals who might lack access to psychiatric care, stressing that legal defenses should be accessible to everyone, regardless of their financial situation.
"To require 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,'" SC said.
It added, "The plea of insanity, as like any other similar defense available under the law, should always be equally accessible to all, regardless of background or status. Adding additional burdens and qualifications to avail them, when not necessary and decisive to the legal issue, is underserving to be branded as a dispensation of justice."
Caguioa ordered the accused's complete evaluation and confinement at the National Center for Mental Health (NCMH) for treatment.
SC said she "may only be released upon the recommendation of her attending physician and approval from the RTC."
