The Supreme Court (SC) has ruled that prior psychiatric records are not required to invoke the insanity defense, recognizing that post-crime evaluations, along with witness testimony and other evidence, can sufficiently establish legal insanity.

In a decision penned by Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division overturned a homicide conviction, upholding that an accused’s mental state at the time of the crime, regardless of when it was assessed, can be grounds for acquittal.

The Court applied the three-pronged test from People v. Paiia, which requires proving that the accused was insane at the time of the crime, the insanity directly caused the act, and the accused was completely deprived of reason or the ability to distinguish right from wrong.

FACTS AND ISSUE

On June 13, 2005, Paulita Bonifacio was killed inside her rented room in Mandaluyong City by her close friend, Mare Claire Ruiz. The two had been close friends, with Bonifacio tutoring Ruiz and later allowing her to stay in her home.

In the days leading up to the killing, Ruiz and Bonifacio engaged in fasting, prolonged prayers, and religious rituals, which the defense later described as indicators of an impending psychotic episode.

On the night of the incident, Ruiz claimed she saw demonic visions, including Bonifacio growing horns and transforming into a devil. Acting under these delusions, she violently attacked Bonifacio, fatally injuring her.

Ruiz was found naked and hysterical at the crime scene, kneeling over Bonifacio’s lifeless body while chanting religious phrases. Witnesses, including her father Carlos Romulo Ruiz and Senior Police Officer I Robert Eugenio, testified that she was incoherent and unresponsive to reality.

Charged with homicide under Article 249 of the Revised Penal Code, Ruiz pleaded not guilty, invoking insanity as a defense.

The Regional Trial Court (RTC) of Mandaluyong City, Branch 208, found Ruiz guilty beyond reasonable doubt, rejecting her insanity plea on the following grounds:

  • She lacked prior psychiatric records proving she was insane before the crime.
  • Some of her actions, such as locking the door with a chain, suggested an awareness of her actions.
  • Her insanity defense relied on post-crime medical evaluations, which the court deemed insufficient to prove her mental state at the time of the offense.

The Court of Appeals (CA) Special Seventeenth Division later affirmed the conviction, ruling that Ruiz failed to establish legal insanity at the time of the crime.

Ruiz appealed to the SC, arguing that her conviction was improper despite clear medical evidence of insanity.

The main issue before the SC was whether the lack of prior psychiatric records prevents an accused from successfully invoking the insanity defense and whether post-crime psychiatric evaluations can establish an accused’s mental state at the time of the offense.

RULING

The SC reversed the conviction, ruling that prior psychiatric records are not necessary to prove legal insanity.

The Court emphasized that clear and convincing evidence—such as post-crime medical evaluations and witness testimony—can sufficiently establish that a defendant lacked criminal responsibility due to insanity.

“Petitioner was able to offer more than clear and convincing evidence to prove her insanity under Article 12(1) of the Revised Penal Code after satisfying all three tests under Paiia, in consonance with relevant laws and jurisprudence. As such, the inescapable conclusion is to exempt petitioner from criminal responsibility,” the decision stated.

Instead of imprisonment, the Supreme Court ordered Ruiz’s confinement at the National Center for Mental Health (NCMH) until she is deemed fit for release by medical experts, subject to court approval. Ruiz was also ordered to pay ₱50,000 in civil indemnity and ₱50,000 in moral damages to Bonifacio’s heirs, plus 6% annual interest until full payment.

Follow Tan Briones & Associates on LinkedIn for more legal updates and law-related articles.