Philippine Law Updates

PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JOSE P. RAGUDO, JR., ACCUSED-APPELLANT. [ G.R. No. 267795, April 15, 2024 ]

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Article 12 of the Revised Penal Code provides that one of the circumstances that is exempt from criminal liability is when a person is insane, unless they have acted during a lucid interval. 

Insanity in the context of this exempting circumstance is defined in People v. Formigones  as being "deprived completely of reason or discernment and freedom of the will at the time of committing the crime."[118]

In determining whether a defense of insanity may prosper, this Court laid down the following three-way test in People v. Paña, thus, clarifying the guidelines in Formigones

Considering the foregoing, we clarify the guidelines laid down in Formigones. Under this test, the insanity defense may prosper if: (1) the accused was unable to appreciate the nature and quality or the wrongfulness of his or her acts; (2) the inability occurred at the time of the commission of the crime; and (3) it must be as a result of a mental illness or disorder.