Insanity plea

Dear Atty. Angela,

I am a street vendor and I have been seeing this woman who is deranged walking around and begging for money. One day, I saw her holding a baby and to my shock, jumped off a bridge. The police officers interviewed me as an eye-witness since the baby died because of what happened. I would just like to know if the mother will be liable for the death of her baby when it is proven that she is not in a normal state of mind.

Anton

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Dear Anton,

In the case of People v. XXX, G.R. No. 273354 (2025), the Supreme Court (SC) acquitted a mother with schizophrenia of parricide over her daughter’s death, ruling that her mental state deprived her of the capacity to recognize the wrongfulness of her act and thus exempted her from criminal liability.

The SC ruled that the mother was not criminally liable because her mental condition during the incident prevented her from understanding the nature and wrongfulness of her actions.

Insanity is defined as a disease or defect of the brain manifested in language or conduct. Under Article 12 of the Revised Penal Code, it is one of the circumstances that exempts a person from criminal liability.

In People v. Paña, G.R. No 214444 (2020), the SC laid down a three-way test to establish insanity as an exempting circumstance: first, the insanity must be present at the time of the commission of the crime; second, it must be medically proven; and third, it must render the accused incapable of appreciating the nature and quality or the wrongfulness of the act.

Insanity must be proven with clear and convincing evidence. As it involves a person’s state of mind, courts look at overt acts or outward behavior. As a rule, insanity must be supported by medical evidence, unless there are extraordinary circumstances where such evidence is not available.

In this case, it is determined that the mother was able to medically prove that she was suffering from schizophrenia at the time of the crime based on the testimony and mental status examination reports from psychiatrists. As such, she is exempt from legal liability.

The SC here ordered the mother’s immediate transfer from the Correctional Institution for Women to the NCMH for treatment.

Atty. Angela Antonio