In Ruiz vs. People (G.R. No. 244692, October 9, 2024), the Supreme Court clarified the requirements to assert legal insanity as a defense in criminal cases. In its decision, the Court ruled that a person does not need a documented history of mental illness to claim insanity as a defense.

The case involved the acquittal of an accused in a homicide case, based on the assertion of insanity at the time of the crime. The accused was charged with homicide after being found naked, covered in blood, and chanting religious phrases over her deceased best friend. She claimed to have attacked her friend after witnessing her transform into a demon and hearing the voice of the Virgin Mary instructing her to place a cross in the victim’s heart.

In its ruling, the SC emphasized that proving legal insanity only requires evidence that the accused was deprived of reason either before, during, or immediately after the commission of the crime, thus:

“To settle this, prior medical records are only relevant, but not the only smoking gun, in proving the second test in Paña. On the other hand, lack thereof, absolutely has nil effect on the defense’s burden to prove a deprivation of intelligence at the time of the commission of the crime, or Paña’s first and third tests.

Second, and more importantly, if the Court were to subscribe to this argument, then it deliberately turns a blind eye to the unfortunate reality that health care is not accessible to majority of the pollution. In fact, the “Court realizes the difficulty and additional burden on the accused to seek psychiatric diagnosis” xxx “

The SC further clarified that while medical records or psychiatric history may serve as helpful evidence, they are not essential to establish legal insanity. In particular, the Court noted that the absence of prior documented psychiatric records should not be held against the accused in asserting insanity as a defense. It emphasized that the absence of such documentation does not negate the possibility of a person suffering from a mental condition that impaired their reasoning at the time of the offense.

This decision sets a precedent that legal insanity can be recognized even in the absence of a formal psychiatric history, so long as there is sufficient evidence showing that the accused was incapable of understanding or controlling her actions due to a mental condition.

For the full text of the decision and press release, you can access the documents through the SC’s official website: https://sc.judiciary.gov.ph/244692-2/