People of the Philippines vs.

Alberto Medina
G.R No. 113691
Facts:

June October 1982, Medina was confined in the National Mental Hospital for
schizophreniform disorder, where he was subsequently released. Relatives say that his
condition did not seem to improve. He was referred to Dr. Adigue for further examinations.
May 20, 1991, 11 pm, a party was attended by both Dalisay and Medina, as well as Larry
Andal, where the both Dalisay and Medina danced the chacha together. Afterwards, Dalisay
invited Andal to go home, with Dalisay walking in front of Larry. They were waylaid by
Medina who stabbed Dalisay. Dalisay fell down and the two grappled on the ground. Dalisay
was able to run away but he was chased and once more stabbed repeatedly by Medina.
Andal was so stunned that he wasnt able to help Dalisay, who was brought DOA to the
hospital.
The Trial Court convicted Medina of murder & said that his defense of insanity is not
meritorious since Dr. Adigue was not qualified as an expert witness, that his sisters
testimony didnt constitute sufficient proof of insanity, and that he was actually mentally
agile during trial.
Issues:
1. Whether or not medina was insane therefore exempt from criminal liability.
2. Whether or not the trial court erred in not appreciating Medinas voluntary
surrender
Rulings:
1. No. The decision was not based on the qualifications of Dr. Adigue as a doctor but
as a witness. What mattered was the failure of Dr. Adigues testimony to establish the legal
insanity of Medina as shown in the results of the tests she conducted which merely says that
Medina has a mild depression and emotional
disturbances. The testimony also did not
establish the complete deprivation of reason on Medinas part. Art. 12, par. 1 of the Revised
Penal Code, requires a complete deprivation of rationality in committing the act; i.e., that
the accused be deprived of reason, that there be no consciousness of responsibility for his
acts, or that there be complete absence of the power to discern. The presumption of law, per
Art. 800 of the Civil Code, always lies in favor of sanity, and, in the absence of proof to the
contrary, every person is presumed to be of sound mind. The defense of insanity or
imbecility must be clearly proved. Hence, in the absence of positive evidence that the
accused had previously lost his reason or was demented moments prior to or during the
perpetration of the crime, the courts will always presume that he was in a normal state of
mind. Care must be taken to distinguish between insanity or lack of reason and failure to use
reason or good judgment due to extreme anger or passion. Moral insanity or mere mental
depravity results not from the disease of the mind but from a perverted condition of the
moral system; person is sane and is not exempted from the criminal liability.
2. The mitigating circumstance of voluntary surrender should have been credited in
favor of the appellant. The solicitor general concurs and notes that appellant, after having
earlier given himself up to a certain Col. Faltado, surrendered at midnight on May 20, 1992,
or about an hour after the stabbing incident, to Wilfredo Sevillano, former desk officer of the
Batangas City Police Station. Hence, the evidence sufficiently established the elements of
voluntary surrender, namely: (1) the offender has not been actually arrested; (2) he
surrendered himself to a person in authority or an agent of a person in authority; and (3) his
surrender was voluntary.