G.R. No. 244692 - Ruiz vs. People

Petitioner Mare Claire Ruiz y Serrano was charged with Homicide for the killing of Paulita Bonifacio y Sumintac on or about June 13, 2005, in Mandaluyong City.
The Information alleged that the petitioner willfully and unlawfully attacked and hit the victim, inflicting fatal wounds causing her death.
Petitioner pleaded not guilty but admitted to the killing under the exempting circumstance of legal insanity.

The defense and prosecution stipulated that the victim died at the victim's rented room at Sta. Ana Street, Mandaluyong City.
The prosecution did not accept the defense's proposed stipulation that petitioner was legally insane.

A reverse trial was held where the defense presented five witnesses, including forensic psychiatrists and the petitioner’s father, to prove insanity.
Defense's testimony outlined petitioner’s deteriorating mental state, characterized by religious delusions, fasting, praying, hallucinations, and belief in possession.
Petitioner’s father found her naked and chanting over the victim's lifeless, bloodied body, with her four fingers inside the victim's mouth.
Defense psychiatrists diagnosed petitioner with psychotic disorder and paranoid schizophrenia, attributing her psychosis to medical conditions like hyponatremia, dehydration, and malnutrition.

Three prosecution witnesses testified, including the medico-legal officer, a priest friend of the victim, and the victim’s sister.
Medico-legal examiner confirmed that victim’s death was caused by traumatic head injuries and fractured ribs caused by blunt force.
Testimonies supported that petitioner and victim were close friends and petitioner was shy and quiet.

RTC found petitioner guilty beyond reasonable doubt of Homicide on June 2, 2016.
RTC rejected insanity defense, finding expert testimonies inconclusive and inconsistent.
The fact that the door to the room where the killing occurred was chained from the inside was interpreted as evidence that petitioner acted consciously to hide the crime.
RTC inferred a possible amorous relationship between petitioner and the victim.

CA affirmed RTC conviction on August 28, 2018, but modified monetary awards.
CA relied on the fact that psychiatric evaluations were post-crime and that chaining the door showed petitioner’s awareness.

Petitioner filed a Petition for Review under Rule 45 to reverse conviction, asserting proof of legal insanity.
Petitioner emphasized fasting, continuous praying, and being naked at the crime scene as evidence of insanity.
Petitioner highlighted expert diagnoses of psychotic disorder and schizophrenia.
The Office of the Solicitor General opposed, arguing that post-crime expert examinations cannot prove insanity at the time of the killing, and described some testimonies about hallucinations as hearsay.

Whether petitioner is exempt from criminal responsibility due to legal insanity as defined under Article 12(1) of the Revised Penal Code.