Case Digest: People v. Pantoja, G.R. No. 223114, November 29, 2017

RELATED TOPIC: Defense of insanity 

FACTS: Pantoja was charged with murder for stabbing a 6-year-old four times using a kitchen knife. He invoked the defense of insanity, claiming that prior to the commission of the crime, he was already exhibiting signs of mental illness. 

ISSUE: Whether Pantoja has clearly and convincingly proven his defense of insanity to exempt him from criminal liability. 

DECISION: No. A scrutiny of the evidence presented by Pantoja fails to establish that he was completely bereft of reason or discernment and freedom of will when he fatally stabbed the victim. The defense of insanity is in the nature of a confession and avoidance, requiring Pantoja to prove it with clear and convincing evidence. 

For purposes of exemption from criminal liability, mere behavioral oddities cannot support a finding of insanity unless the totality of such behavior indubitably shows a total absence of reason, discernment, or free will at the time the crime was committed. 

For the defense of insanity to prosper, two elements must concur: (1) that defendant’s insanity constitutes a complete deprivation of intelligence, reason, or discernment; and (2) that such insanity existed at the time of, or immediately preceding, the commission of the crime. 

In this case, while the evidence of the accused does not show that he was completely deprived of intelligence or consciousness of his acts when he committed the crime, there is sufficient indication that he was suffering from some impairment of his mental faculties; thus, he may be credited with the mitigating circumstance of diminished willpower.

 Read the full case here

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