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PEOPLE v. ROGER AUSTRIA Y NAVARRO

This case has been cited 4 times or more.

	GR Nos. 147674-75 2004-03-17	PEOPLE v. ANACITO OPURAN DAVIDE JR., C.J.
claims that he is not guilty because he is insane. The testimony or proof of an accused's insanity must, however, relate to the time immediately preceding or coetaneous with the commission of the offense with which he is charged.[30] It is, therefore, incumbent upon accused's counsel to prove that his client was not in his right mind or was under the influence of a sudden attack of insanity immediately before or at the time he executed the act attributed to him.[31] Since insanity is a condition of the mind, it is not susceptible of the usual means of proof. As no man can know what is going on in the mind of another, the state or condition of a person's mind can only be measured and judged by his behavior.[32] Thus,
	GR No. 130487 2000-06-19	PEOPLE v. ROBERTO ESTRADA PUNO, J.
Since the presumption is always in favor of sanity, he who invokes insanity as an exempting circumstance must prove it by clear and positive evidence.[51] And the evidence on this point must refer to the time preceding the act under prosecution or to the very moment of its execution.[52]
	GR No. 130487 2000-06-19	PEOPLE v. ROBERTO ESTRADA PUNO, J.
If the mental examination on accused-appellant had been promptly and properly made, it may have served a dual purpose[89] by determining both his competency to stand trial and his sanity at the time of the offense. In some Philippine cases, the medical and clinical findings of insanity made immediately after the commission of the crime served as one of the bases for the acquittal of the accused.[90] The crime in the instant case was committed way back in December 1994, almost six (6) years ago. At this late hour, a medical finding alone may make it impossible for us to evaluate appellant's mental condition at the time of the crime's commission for him to avail of the exempting circumstance of insanity.[91] Nonetheless, under the present circumstances, accused-appellant's competence to stand trial must be properly ascertained to enable him to participate in his trial meaningfully.