People v. Dungo, 199 SCRA 860 (1991)

People vs.
Dungo
Facts:
 On March 16, 1987 between 2:00 and 3:00pm, the accused went to Mrs. Sigua's office at the
Department of Agrarian Reform, Apalit, Pampanga.
 After a brief talk, the accused drew a knife from the envelope he was carrying and stabbed Mrs.
Sigua several times. After which he departed from the office with blood stained clothes, carrying
a bloodied bladed weapon.
 The autopsy report revealed that the victim sustained 14 wounds, 5 of which were fatal.
 Rodolfo Sigua, husband of the deceased, testified that sometime in February 1987, the accused
Rosalino Dungo inquired from him why his wife was requiring so many documents from him.
Rodolfo explained to him the procedure at the DAR.
 The accused, in defense of himself, tried to show that he was insane at the time of the
commission of the offense:
 Two weeks prior to March 16, 1987, Rosalino's wife noticed that he appears to be in deep
thought always, maltreating their children when he was not used to it before. There were also
times that her husband would inform her that his feet and head were on fire when in truth they
were not.
 On that fateful day, Rosalino complained of stomachache but they didn't bother to buy medicine
as the pain went away immediately. Thereafter, he went back to the store. But when Andrea
followed him to the store, he was no longer there. Worried, she looked for him. On her way
home, she heard people saying that a stabbing occurred.
 She saw her husband in her parentsin-law's house with people milling around. She asked her
husband why he did the act, to which Rosalino answered, "That's the only cure for my ailment. I
have cancer of the heart. If I don't kill the deceased in a number of days, I would die.
 That same day, the accused went to Manila.
 Dr. Santiago and Dr. Echavez of the National Center for Mental Health testified that the accused
was confined in the mental hospital, as per order of the trial court dated Aug. 17, 1987.
 Based on the reports of their staff, they concluded that Rosalino was psychotic or insane long
before, during and after the commission of the alleged crime and classified his insanity as an
organic mental disorder secondary to cerebro-vascular accident or stroke.
 But Dr. Balatbat who treated the accused for ailments secondary to stroke, and Dr. Lim who
testified that the accused suffered dorm occlusive disease, concluded that Rosalino was
somehow rehabilitated after a series of medical treatment in their clinic.
Issue:
 WON the accused was insane during the commission of the crime charged.
Held:
 No. For insanity to relieve the person of criminal liability, it is necessary that there be a complete
deprivation of intelligence in committing the act, that he acts without the least discernment and
that there be complete absence of deprivation of the freedom of the will.
 Under Philippine jurisdiction, there's no definite test or criterion for insanity. However, the
definition of insanity under Sec 1039* of the Revised Administrative Code can be applied. In
essence, it states that insanity is evinced by a deranged and perverted condition of the mental
faculties, which is manifested in language or conduct. An insane person has no full and clear
understanding of the nature and consequence of his act.
 Evidence of insanity must refer to the mental condition at the very time of doing the act.
However, it is also permissible to receive evidence of his mental condition for a reasonable
period before and after the time of the act in question. The vagaries of the mind can only be
known by outward acts.
 It is not usual for an insane person to confront a specified person who may have wronged him.
But in the case at hand, the accused was able to with Mrs. Sigua. From this, it can be inferred
that the accused was aware of his acts.
 This also established that the accused has lucid intervals.
 Moreover, Dr. Echavez testified to the effect that the appellant could have been aware of the
nature of his act at the time he committed it when he shouted (during laboratory examination)
that he killed Mrs. Sigua. This statement makes it highly doubtful that the accused was insane
when he committed the act.
 The fact that the accused was carrying an envelope where he hid the fatal weapon, that he ran
away from the scene of the incident after he stabbed the victim several times, that he fled to
Manila to evade arrest, indicate that he was conscious and knew the consequences of his acts in
stabbing the victim. (This was taken from the trial court's decision).
 Judgment: Questioned decision AFFIRMED.

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