Case Digest (G.R. No. 132319)
Facts:
People of the Philippines v. Fernando Madarang y Magno, G.R. No. 132319, May 12, 2000, First Division, Puno, J., writing for the Court. The accused-appellant Fernando Madarang y Magno was charged with parricide under Art. 246, Revised Penal Code for stabbing his wife, Lilia M. Madarang, on September 3, 1993. At arraignment the accused refused to plead and the trial court entered a plea of "not guilty" for him; at the initial hearing his counsel informed the court of observed abnormal behavior while the accused was in provincial jail. The trial court ordered a psychiatric evaluation at the National Center for Mental Health (NCMH) on May 5, 1994 to determine fitness to stand trial.The NCMH confinement produced three psychiatric evaluations. The first (Aug. 2, 1994) diagnosed schizophrenia; the second (Dec. 21, 1994) maintained that diagnosis; after treatment the third (May 27, 1996) reported considerable improvement and recommended discharge to recommit the accused to jail as fit to stand trial. The accused was discharged from NCMH and returned to provincial jail on June 19, 1996.
A reverse trial was conducted on the sole issue of insanity at the time of the offense. The defense offered the accused’s testimony and witnesses including his daughter and mother-in-law, Avelina Mirador, and psychiatric testimony from Dr. Wilson S. Tibayan, who opined the accused suffered schizophrenia and that the illness might have begun prior to the killing. The factual background: Madarang was a former seaman who lost his business and fortune; his family lived with his mother-in-law; on Sept. 3, 1993 he quarreled with his pregnant wife over alleged infidelity and stabbed her, causing instantaneous death; witnesses saw him emerge holding a bolo and flee. The mother-in-law testified she had not noticed prior abnormal behavior.
The trial court convicted the accused, finding he failed to rebut the presumption of sanity at the time of...(Pro-only)
Issues:
- Did the accused successfully rebut the presumption of sanity and thereby establish insanity as an exemption from criminal liability at the time he committed the offense?
- May post-offense psychiatric diagnosis and confinement be accorded weight in proving insanity at the time of the offense absent proof of abnormal behavior immediately before or during...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)