PEOPLE OF THE PHILIPPINES vs AQUINO

(G.R. No. 87084, June 27, 1990)

Facts:
Juanito Q. Aquino, the accused-appellant was charged with rape with homicide before the
RTC Branch 57 in San Carlos, Pangasinan. Aquino willfully, unlawfully and feloniously had
sexual intercourse with Carmelita alias Carmen Morado, 18 years old, and then struck her with a
stone which directly caused her death afterwards.
Armando Frias, a police officer of PNP Pangasinan was able to secure a statement from
Morado before she died. She positively identified and named Juanito Aquino as the same person
who raped and struck her.
Before the preliminary investigation, Aquino said he had no access to a lawyer, so Atty.
Liliosa Rosario of the CItizend Legal Assistance Office was called upon to assist him. However,
before the accused could be arraigned, they filed a Motion to Commit the accused-appellant to
the National Center for Mental Health which was then granted by the Court.
Aquino was then arraigned after being released and pleaded not guilty and put up
insanity as his defense. He was later on sentenced to life imprisonment and pay P 35,000.00 as
damages.
Issue:
Whether or not accused-appellant, who has invoked insanity as his defense, had
overcome the presumption of sanity.
Ruling:
Although Dr. Nicanor L. Echavez diagnosed the accused-appellant with a condition
described as organic mental disorder with psychosis, he stated that an insane person may still
know what he is doing is wrong. Furthermore, he testified that there is no possibility of the
accused-appellant to have lucid intervals.
The law presumes that everyone charged with crime is sane and thus, the burden of proof
is on the defense. As no man can look into the mind of another, the state of mind of a person can
only be measured by its external acts. According to several testimonies from persons closely
acquainted with Aquino, he always appeared to be normal, responsive to conversation, did not
exercise any queer behavior, and was appropriately dressed during the time of his arrest. He also
admitted that during his time in the Mental Health Institution that he had consumed 120cc (mL)
of cough syrup and 3 sticks of Marijuana. It was therefore, appropriate that the Court ruled that
there was not enough evidence to support his defense, for he was even able to recall such details,
which shows he wasnt deprived of his reasoning faculties and sound judgment.

The Supreme Court modified the term used in the RTC decision from life
imprisonment to reclusion perpetua, under the scheme of penalties in the revised penal code,
and reduced the civil indemnity from P 35,000.00 to P 30,000.00.