THE Supreme Court has acquitted a mother previously convicted of parricide over the death of her 5-year-old daughter, ruling that her schizophrenia rendered her legally insane at the time of the incident and exempted her from criminal liability.
In a decision penned by Associate Justice Samuel Gaerlan, the Court’s Third Division granted the mother’s appeal to reverse previous rulings by lower courts, finding that her mental condition deprived her of the capacity to understand the nature and wrongfulness of her actions.
The case stemmed from an incident in which the mother jumped off a bridge into a river while holding her child. She was rescued by a passerby on a makeshift banca, but the child went missing and was found dead the following day.
The mother testified she had no recollection of the incident, recalling only that she had been walking with her daughter before regaining consciousness in the water. A psychiatrist from the National Center for Mental Health diagnosed her with schizophrenia.
A regional trial court had convicted her of parricide and sentenced her to reclusion perpetua, or up to 40 years of imprisonment, concluding she intended to harm the child.
The Court of Appeals upheld the conviction.
The high court, however, ruled that the requirements for legal insanity were met under Article 12 of the Revised Penal Code of the Philippines, which exempts persons from criminal liability if they are incapable of appreciating the nature or wrongfulness of their acts at the time of the crime.
Citing jurisprudence, the Court reiterated that insanity must be present during the commission of the act, medically established and sufficient to deprive the accused of discernment.
The Court found these conditions satisfied, giving weight to psychiatric evaluations and testimony that the mother exhibited paranoia and delusions, including perceived threats and hostility from others, at the time of the incident.
“Schizophrenia is a chronic mental disorder marked by an inability to distinguish reality from fantasy,” the Court said, noting that such a condition can impair judgment and awareness of one’s actions.
Despite the acquittal, the Court held the mother civilly liable and ordered her to pay the victim’s heirs P75,000 in civil indemnity and P200,000 in combined moral, exemplary and temperate damages.
The Court also directed her transfer from the Correctional Institution for Women to the National Center for Mental Health for treatment. Her release will depend on a regional trial court order, based on the recommendation of her attending physician.
