MANILA – The Supreme Court (SC) has ruled that a person does not need a documented history of mental illness to claim legal insanity as a defense.

In a decision promulgated on Oct. 9, 2024, the SC’s Third Division acquitted an accused due to insanity and ordered her confinement at the National Center for Mental Health (NCMH) for treatment.

Court records showed that the accused was charged with homicide after her father found her naked, covered in blood, and chanting religious phrases over her best friend’s corpse.

She claimed she attacked her best friend after she saw her grow horns and transform into a demon.

She also reported hearing the Virgin Mary’s voice instructing her to place a cross into the victim’s heart, among other commands.

Both the Regional Trial Court (RTC) and the Court of Appeals found the accused guilty, rejecting her defense of insanity.

They ruled that the medical assessment should have evaluated her mental state before, during, and after the crime.

In overturning their rulings, the SC ruled that the accused showed enough evidence of insanity at the time of the crime.

The SC clarified that proving legal insanity only requires evidence that the accused was deprived of intelligence either before, during, or immediately after the crime.

It said that while prior medical records can be relevant, they are not required to prove that the accused’s medical condition led to the crime.

“Therefore, the absence of documented psychiatric history should not be taken against the accused claiming legal insanity,” it said.

The high tribunal also acknowledged the unfair burden on impoverished individuals who may not have access to psychiatric care, emphasizing that legal defenses should be equally available to all.

“To require prior medical records puts the impoverished at a disadvantaged position, who, due to circumstances beyond their control, are forced to brush aside conditions of their health in order to prioritize the immediate need to put food on the table and other necessities,” the SC said.

“The plea of insanity, as like any other similar defense available under the law, should always be equally accessible to all, regardless of background or status. Adding additional burdens and qualifications to avail them, when not necessary and decisive to the legal issue, is underserving to be branded as a dispensation of justice.”

While the accused was exempted from imprisonment, the SC ordered her confinement in the NCMH for full evaluation and treatment.

She may only be released upon the recommendation of her attending physician and approval from the RTC. (PNA)