28/04/2026
SUPREME COURT ACQUITS MOTHER WITH SCHIZOPHRENIA OF PARRICIDE IN DAUGHTERโS DEATH, CITES LEGAL INSANITY
The Supreme Court (SC) has acquitted a mother with schizophrenia of parricide, saying her mental state at the time of her child's death "deprived her of the capacity to recognize the wrongfulness of her act," which exempts her from criminal liability.
In a 14-page decision penned by Associate Justice Samuel Gaerlan, the SC's Third Division has reversed the ruling of the Court of Appeals (CA), which convicted a mother of parricide for the death of her daughter, ordering her treatment in a psychiatric facility.
The mother jumped off a bridge into a river with her five-year-old daughter. While a man aboard a styrofoam banca was able to save the mother, he was unable to locate the child, whose lifeless body was found 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) convicted the mother and sentenced her to reclusion perpetua or up to 40 years in prison. It was found that she intended to harm her daughter when she jumped off the bridge while embracing her. The Court of Appeals affirmed the RTCโs decision.
In reversing the rulings of the CA and RTC, the high court noted that the motherโs mental state deprived her of the capacity to recognize the wrongfulness of her act and thus exempted her from criminal liability.
It noted that Article 12 of the Revised Penal Code provides that insanity is a disease or defect of the brain manifested in language or conduct. The same is a circumstance that exempts a person from criminal liability.
The SC cited the case of People v. Paรฑa, which 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.
It underscored that, as a general 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 found 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.
It 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 Paรฑa doctrine.
The highest bench gave great weight to the testimony of a psychiatrist who said 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 victimโs heirs PHP 75,000 in civil indemnity and PHP 200,000 in moral, exemplary, and temperate damages.
The high tribunal ordered the motherโs 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.
