G.R. No. 167109 - Amor-Catalan vs. Court of Appeals

Fernando Madarang y Magno was charged with parricide for the killing of his wife, Lilia Madarang, as set forth in the Information which detailed the stabbing incident on September 3, 1993, in Infante, Pangasinan.
At arraignment, the accused refused to enter a plea, prompting the court to enter a “not guilty” plea on his behalf.
During the initial hearing on May 5, 1994, abnormal behavior was observed by the accused's counsel while he was in jail, leading the court to order his transfer to the National Center for Mental Health (NCMH) for a psychiatric evaluation regarding his fitness to stand trial.

Upon examination at the NCMH, Fernando Madarang was diagnosed with schizophrenia—a form of psychosis characterized by impaired reasoning, delusions, hallucinations, and disturbances in self-care, insight, and judgment.
Multiple psychiatric evaluations were performed:

The first evaluation (August 2, 1994) confirmed a state of insanity due to schizophrenia.
A second report (by December 21, 1994) reiterated that he was still suffering from schizophrenia.
A third evaluation (May 27, 1996) noted noticeable improvement in his mental condition due to continuous medication, recommending discharge and recommitment to jail since he was deemed fit for trial.

Despite the diagnosis post-incident, witnesses (including his mother-in-law) did not observe obvious signs of mental disturbance immediately preceding or during the commission of the crime.

Fernando Madarang was a legitimate husband to Lilia, and they had seven children.
His employment history included working as a seaman for 16 years and later venturing into a hardware business which eventually failed.
Financial loss and dependence on his mother-in-law ensued, contributing to familial strife.

A quarrel between Fernando and his wife, allegedly spurred by accusations of infidelity and jealousy, escalated in the presence of their children.
The accused stabbed his wife with a bolo, inflicting fatal wounds.
Witnesses, including Avelina Mirador (mother-in-law) and her nephew, testified that he emerged from the house wielding a bolo and displayed behavior that did not conclusively indicate a loss of sanity.

The accused claimed to have no recollection of the stabbing incident, learning of his wife’s death only later when shown a photograph.
His mother-in-law testified that no peculiar behavior was noted during the stay in her house prior to the incident.
Expert testimony, particularly that of Dr. Wilson S. Tibayan, elaborated on the nature of schizophrenia, noting that while schizophrenics may exhibit irregular behavior, they can also experience lucid intervals.

The defense argued that the accused, during the crime, was completely deprived of intelligence and thus incapable of rational control, invoking his state of schizophrenia.
Specific points raised by the defense included:

His complete lack of recollection concerning the stabbing incident.
Evidence that his violent behavior during the incident was symptomatic of his schizophrenic state.
The possibility that his mental illness predated the incident due to personal and financial crises.

There was no evidence of abnormal or bizarre behavior immediately before or during the commission of the crime.
The absence of such proximate evidence rendered the defense’s arguments speculative and non-sequitur.

The trial court convicted Fernando Madarang, ruling that the evidence was sufficient to uphold the presumption of sanity at the time of the offense.
In its decision, the trial court declared the accused of sound mind during the commission of the parricide, rendering his claim of insanity unconvincing.
Consequently, the appellate court affirmed the conviction, sentencing him to reclusion perpetua and ordering him to pay P50,000 to the heirs of the victim.

Whether the accused, by invoking an insanity defense, can be exempted from criminal liability due to schizophrenia affecting his capacity to distinguish right from wrong at the time of the offense.
Whether post-incident psychiatric evaluations and evidence reflecting a diagnosis of schizophrenia are sufficient to rebut the presumption of sanity, particularly in the absence of clear behavioral irregularities immediately before or during the commission of the crime.
The appropriate application of various legal tests (such as the M’Naghten rule and its iterations) in determining criminal responsibility in cases where insanity is alleged.