The Supreme Court has acquitted a mother charged with parricide, ruling that she was legally insane at the time of the crime due to schizophrenia. In a decision penned by Associate Justice Samuel H. Gaerlan of the Third Division, the Court held that the mother lacked the capacity to understand the wrongfulness of her actions, exempting her from criminal liability under Article 12 of the Revised Penal Code.
Details of the Case
The case, People v. XXX (G.R. No. 273354, Oct. 29, 2025), involved a mother who jumped off a bridge while carrying her five-year-old daughter. A bystander on a styrofoam boat rescued the mother, but the child was not found until the next day, when her body was discovered floating in the river. The mother later testified that she was not in her right mind at the time, recalling only walking with her daughter and not remembering the jump. She regained consciousness while floating in the water.
Medical Evidence
A licensed psychiatrist from the National Center for Mental Health (NCMH) testified that the mother suffered from schizophrenia, a chronic mental disorder that impairs a person's ability to distinguish reality from fantasy. The Regional Trial Court (RTC) had convicted the mother and sentenced her to reclusion perpetua, finding that she intended to harm the child when she jumped while embracing her. The Court of Appeals affirmed the conviction.
Supreme Court Ruling
The Supreme Court reversed the lower courts, applying the three-part test from People v. Paña to determine insanity as an exempting circumstance: (1) the insanity must exist at the time of the crime, (2) it must be proven by qualified medical experts, and (3) due to insanity, the accused must be unable to know that their act was wrong. The Court found all three requirements satisfied, noting that the mother's schizophrenia was established by psychiatric testimony and mental status examination reports.
Civil Liability and Treatment
While the mother was acquitted of criminal liability, the Court ordered her to pay the victim's heirs P75,000 in civil indemnity and P200,000 in moral, exemplary, and temperate damages. She was transferred from the Correctional Institution for Women to the NCMH for treatment, and may only be released upon order of the RTC based on the recommendation of her attending physician.
