People v. Fernando Madarang y Magno

Summary

Fernando Madarang was charged with parricide for stabbing his pregnant wife Lilia to death on September 3, 1993, in Pangasinan. He invoked the insanity defense, claiming complete deprivation of intelligence at the time of the crime. After exhibiting abnormal behavior, he was committed to the National Center for Mental Health where he was diagnosed with schizophrenia. However, both the trial court and Supreme Court rejected his insanity defense. The Supreme Court emphasized that Philippine law requires proof of complete deprivation of intelligence, and that the evidence must relate to the time of commission of the crime. Finding no evidence of abnormal behavior immediately before or during the crime, and noting that schizophrenics have lucid intervals, the Court affirmed his conviction for parricide and sentence of reclusion perpetua. The case establishes important precedent on the stringent requirements for the insanity defense in Philippine criminal law.