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PEOPLE v. GUILLERMO FLORENDO

This case has been cited 3 times or more.

2012-10-11
PERALTA, J.
In the instant case, petitioner was able to substantially prove that Jacinto's death was attributable to his deliberate act of killing himself by jumping into the sea.  Meanwhile, respondent, other than her bare allegation that her husband was suffering from a mental disorder, no evidence, witness, or any medical report was given to support her claim of Jacinto's insanity.  The record does not even show when the alleged insanity of Jacinto did start. Homesickness and/or family problems may result to depression, but the same does not necessarily equate to mental disorder.  The issue of insanity is a question of fact; for insanity is a condition of the mind not susceptible of the usual means of proof.  As no man would know what goes on in the mind of another, the state or condition of a person's mind can only be measured and judged by his behavior.  Establishing the insanity of an accused requires opinion testimony which may be given by a witness who is intimately acquainted with the person claimed to be insane, or who has rational basis to conclude that a person was insane based on the witness' own perception of the person, or who is qualified as an expert, such as a psychiatrist.[8]  No such evidence was presented to support respondent's claim.
2010-06-29
VELASCO JR., J.
The aforementioned circumstances are not easily available to an accused as a successful defense. Insanity is the exception rather than the rule in the human condition.[19] While Art. 12(1) of the Revised Penal Code provides that an imbecile or insane person is exempt from criminal liability, unless that person has acted during a lucid interval, the presumption, under Art. 800 of the Civil Code, is that every human is sane. Anyone who pleads the exempting circumstance of insanity bears the burden of proving it[20] with clear and convincing evidence.[21] It is in the nature of confession and avoidance. An accused invoking insanity admits to have committed the crime but claims that he or she is not guilty because of insanity. 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.[22]  We agree with the Solicitor General that the mental records Tibon wishes to support his defense with are inapplicable to the theory he espouses. The NCMH records of his mental health only pertain to his ability to stand trial and not to his mental state immediately before or during the commission of the crimes.
2009-03-02
CHICO-NAZARIO, J.
Insanity exists when there is a complete deprivation of intelligence while committing the act; i.e., when the accused is deprived of reason, he acts without the least discernment because there is a complete absence of power to discern, or there is total deprivation of freedom of the will.  Mere abnormality of the mental faculties is not enough, especially if the offender has not lost consciousness of his acts. Insanity is evinced by a deranged and perverted condition of the mental faculties and is manifested in language and conduct.  An insane person has no full and clear understanding of the nature and consequences of his or her acts.[25]