EXEMPTING CIRCUMSTANCES per order of the trial court dated Aug. 17, 1987.
PEOPLE VS DUNGO Based on the reports of their staff, they
concluded that Rosalino was psychotic or
Facts: insane long before, during and after the
On March 16, 1987 between 2:00 and commission of the alleged crime and classified
3:00pm, the accused went to Mrs. Sigua's office his insanity as an organic mental disorder
at the Department of Agrarian Reform, Apalit, secondary to cerebro-vascular accident or
Pampanga. After a brief talk, the accused drew stroke. But Dr. Balatbat who treated the
a knife from the envelope he was carrying and accused for ailments secondary to stroke, and
stabbed Mrs. Sigua several times. After which Dr. Lim who testified that the accused suffered
he departed from the office with blood stained dorm occlusive disease, concluded that
clothes, carrying a bloodied bladed weapon. Rosalino was somehow rehabilitated after a
The autopsy report revealed that the victim series of medical treatment in their clinic.
sustained 14 wounds, 5 of which were fatal.
Issue: Whether or not the accused was insane
Rodolfo Sigua, husband of the deceased, during the commission of the crime charged.
testified that sometime in February 1987, the
accused Rosalino Dungo inquired from him why Held:
his wife was requiring so many documents from No. For insanity to relieve the person of
him. Rodolfo explained to him the procedure at criminal liability, it is necessary that there be a
the DAR. complete deprivation of intelligence in
committing the act, that he acts w/o the least
The accused, in defense of himself, tried to discernment and that there be complete
show that he was insane at the time of the absence or deprivation of the freedom of the will.
commission of the offense:
Two weeks prior to March 16, 1987, Under Philippine jurisdiction, there's no
Rosalino's wife noticed that he appears to be definite test or criterion for insanity. However,
in deep thought always, maltreating their the definition of insanity under Sec 1039* of the
children when he was not used to it before. Revised Administrative Code can be applied. In
There were also times that her husband essence, it states that insanity is evinced by a
would inform her that his feet and head were deranged and perverted condition of the mental
on fire when in truth they were not. faculties, which is manifested in language or
On that fateful day, Rosalino complained of conduct. An insane person has no full and clear
stomachache but they didn't bother to buy understanding of the nature and consequence
medicine as the pain went away immediately. of his act.
Thereafter, he went back to the store. But
when Andrea followed him to the store, he Evidence of insanity must refer to the
was no longer there. Worried, she looked for mental condition at the very time of doing the
him. On her way home, she heard people act. However, it is also permissible to receive
saying that a stabbing occurred. She saw her evidence of his mental condition for a
husband in her parents-in-law's house with reasonable period before and after the time of
people milling around. She asked her the act in question. The vagaries of the mind can
husband why he did the act, to which only be known by outward acts.
Rosalino answered, "That's the only cure for
my ailment. I have cancer of the heart. If I It is not usual for an insane person to
don't kill the deceased in a number of days, I confront a specified person who may have
would die.” That same day, the accused went wronged him. But in the case at hand, the
to Manila. accused was able to confront Mrs. Sigua. From
this, it can be inferred that the accused was
Dr. Santiago and Dr. Echavez of the National aware of his acts. This also established that the
Center for Mental Health testified that the accused has lucid intervals.
accused was confined in the mental hospital, as
Moreover, Dr. Echavez testified to the
effect that the appellant could have been aware
of the nature of his act at the time he committed
it when he shouted (during laboratory
examination) that he killed Mrs. Sigua. This
statement makes it highly doubtful that the
accused was insane when he committed the
act.
The fact that the accused was carrying an
envelope where he hid the fatal weapon, that he
ran away from the scene of the incident after he
stabbed the victim several times, that he fled to
Manila to evade arrest, indicate that he was
conscious and knew the consequences of his
acts in stabbing the victim.
