Ruiz v. People

Summary

Mare Claire Ruiz was charged with homicide for killing her friend Paulita Bonifacio in 2005. The defense claimed legal insanity, presenting evidence that Ruiz suffered from Schizophrenia, Paranoid Type, and was experiencing psychotic episodes during intensive religious activities. The RTC and CA convicted her, rejecting the insanity defense based on post-crime psychiatric evaluations and inferences about her conduct. The Supreme Court reversed, finding clear and convincing evidence of legal insanity under the three-part test from People v. Paña. The Court emphasized that deprivation of intelligence can be proven through behavior immediately before, during, or after the crime, and that prior psychiatric records are not required. Ruiz was acquitted but ordered confined for treatment while remaining civilly liable for damages.