28/04/2026
Ever since the pandemic, mental health
issues have been on the rise so this
SC decision dovetails this trend.
Here is our QUESTION FOR REFLECTION-
"Do you think the three-way test in People v. Pana is strict enough to prevent abuse of the insanity defense?"
Source: SC Public Information Office
The (SC) has acquitted a mother of parricide over her daughter’s death, exempting her from criminal liability after finding that she has schizophrenia and her mental state deprived her of the capacity to recognize the wrongfulness of her act.
In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division granted a mother’s appeal and overturned her parricide conviction on the ground of legal insanity due to schizophrenia, an exempting circumstance under the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦.
The mother was charged with parricide for the killing of her five-year old daughter after she was seen embracing the child and simultaneously jumping off a bridge into a river with her, which led to her daughter’s death. While a man aboard a styrofoam banca was able to save the mother, he was unable to locate the child. The daughter’s lifeless body was found in the river the next day.
The mother claimed she was not in her right mind at the time. She could only remember walking with her daughter and had no memory of the incident itself. She said she only regained consciousness while floating in the water.
A licensed physician from the National Center for Mental Health (NCMH) testified that the mother was diagnosed with schizophrenia.
The Regional Trial Court (RTC) brushed aside the claim of insanity as she entered into a plea of “not guilty” and raised insanity as a defense only after the prosecution rested its case. The RTC convicted the mother and sentenced her to reclusion perpetua after finding that she was sane at the time of the incident.
The Court of Appeals affirmed the RTC’s decision.
The SC disagreed. It ruled that the mother was not criminally liable because her mental condition during the incident prevented her from understanding the nature and wrongfulness of her actions.
Insanity is defined as a disease or defect of the brain manifested in language or conduct. Under Article 12 of the Revised Penal Code, it is one of the circumstances that exempts a person from criminal liability.
In 𝙋𝙚𝙤𝙥𝙡𝙚 𝙫. 𝙋𝙖ñ𝙖, the SC laid down a three-way test to establish insanity as an exempting circumstance:
• 𝙛𝙞𝙧𝙨𝙩, the insanity must be present at the time of the commission of the crime;
• 𝙨𝙚𝙘𝙤𝙣𝙙, it must be medically proven; and
• 𝙩𝙝𝙞𝙧𝙙, it must render the accused incapable of appreciating the nature and quality or the wrongfulness of the act.
Insanity must be proven with clear and convincing evidence. Because it involves a person’s state of mind, courts look at overt acts or outward behavior. As a rule, insanity must be supported by medical evidence, unless there are extraordinary circumstances where such evidence is not available. While people who know the accused may testify about their observations, courts give greater weight to the findings and evaluations of qualified medical experts.
In this case, the SC determined that the mother was able to medically prove that she was suffering from schizophrenia at the time of the crime based on the testimony and mental status examination reports from psychiatrists.
The SC further explained that schizophrenia is a chronic mental disorder characterized by the inability to distinguish between fantasy and reality. Often accompanied by hallucinations and delusions, the medical condition deprives a person of discernment, satisfying the third requisite in the 𝘗𝘢ñ𝘢 𝘥𝘰𝘤𝘵𝘳𝘪𝘯𝘦.
Here, the psychiatrist testified that the mother was mentally disturbed at the time of the incident, showing signs of paranoia and perceiving threats, gossip, and envy directed at her.
While the SC exempted the mother from criminal liability, it still held her civilly liable and ordered her to pay the victim’s heirs PHP 75,000 in civil indemnity and PHP 200,000 in moral, exemplary, and temperate damages.
The SC also ordered the mother’s immediate transfer from the Correctional Institution for Women to the NCMH for her treatment. She will be released only upon the order of the RTC based on a recommendation from her attending physician at the hospital.
Read the full text of the press release at https://sc.judiciary.gov.ph/?p=164320
Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164308
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