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.
In a decision written by Associate Justice Samuel Gaerlan and made public April 27, the SC’s Third Division granted a mother’s appeal and overturned her parricide conviction on the ground of legal insanity due to schizophrenia.
The case involved an incident where the mother jumped off a bridge into a river with her five-year-old daughter. While a man aboard a styrofoam banca was able to save the mother, he was unable to locate the child. The daughter’s lifeless body was found in the river the next day.
The mother claimed she was not in her right mind at the time. She could only remember walking with her daughter and had no memory of the incident itself. She said she only regained consciousness while floating in the water.
A licensed physician from the National Center for Mental Health (NCMH) testified that the mother was diagnosed with schizophrenia.
The Regional Trial Court (RTC) convicted the mother and sentenced her to reclusion perpetua or up to 40 years in prison. It found that she intended to harm her daughter when she jumped off the bridge while embracing her.
The Court of Appeals affirmed the RTC’s decision.
But the SC disagreed. It 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, the SC said. 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, 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.
In this case, the SC 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.
The SC further explained that schizophrenia is a chronic mental disorder characterized by the inability to distinguish between fantasy and reality. Often accompanied by hallucinations and delusions, the medical condition deprives a person of discernment, satisfying the third requisite in the Paña doctrine.
Here, the psychiatrist testified that the mother was mentally disturbed at the time of the incident, showing signs of paranoia and perceiving threats, gossip, and envy directed at her.
While the SC exempted the mother from criminal liability, it still held her civilly liable and ordered her to pay the victim’s heirs P75,000 in civil indemnity and P200,000 in moral, exemplary, and temperate damages.
It also ordered the mother’s immediate transfer from the Correctional Institution for Women to the NCMH for her treatment, the SC Office of the Spokesperson said in a press release.
She will be released only upon the order of the RTC, based on a recommendation from her attending physician at the hospital, it added. ||
