FACTS:

Melecio Robiños was charged with the complex crime of parricide with unintentional abortion for killing his pregnant wife, Lorenza Robiños, and the fetus inside her. The prosecution presented the testimony of Lorenzo Robiños, the couple's son, who witnessed the incident. According to Lorenzo, he heard his parents quarreling in their house and saw his mother tell appellant to leave. Appellant then stabbed Lorenza on the right shoulder with a double-bladed knife, causing her to fall to the floor. Lorenzo immediately left their house and went to his grandmother's house to report the incident. Benjamin Bueno, the victim's brother, also testified and stated that he received news of his sister's death from neighbors. He saw appellant and heard him shout at him before seeking help from Barangay Captain Virgilio Valdez and the police. The police found appellant embracing his wife's body on the floor, and he was holding a bloodstained knife and uttering words of self-harm. Lorenza was already dead, and appellant admitted to a neighbor that he had killed his wife. Appellant was arrested and hospitalized for a stab wound. After the incident, a Special Report was prepared by the Chief of Police, which detailed the events of the crime.

In addition, it was established that Lorenza Robiños was six months pregnant and suffered 41 stab wounds on different parts of her body. The suspect, Melecio Robiños, who was under the influence of alcohol, argued with his wife until he became irked and stabbed her multiple times using a double knife. The suspect also stabbed himself and was brought to the hospital. A knife was recovered from the crime scene. During the trial, the prosecution failed to present the doctor who conducted the autopsy and the autopsy report as evidence.

The defense argued that the accused, Melecio Robiños, was insane at the time of the crime. The defense presented testimonies from the accused's son, a nurse, and two detention prisoners who observed the accused exhibiting unusual behavior. The accused himself testified that he did not remember being charged with the crime and could not believe that he killed his wife.

Due to the penalty imposed by the trial court, the case was elevated to the higher court for review.

ISSUES:

1. Whether the court erred in disregarding the accused-appellant's defense of insanity.

2. Whether insanity can be considered as an exempting circumstance.

3. Whether the defense of insanity was proven by the accused at the time of the commission of the crime.

4. Whether the proper penalty was imposed by the trial court.

5. Whether the penalty for the crime of parricide should be reduced to reclusion perpetua due to the absence of aggravating or mitigating circumstances.

RULING:

1. The appeal is partly meritorious. The court acknowledges the undisputed fact that the accused killed his wife. However, the accused interposed the defense of insanity to absolve himself of criminal liability. Insanity is a defense that requires the accused to establish that they were completely deprived of reason or discernment and freedom of will at the time of the crime. The accused has the burden of proving their insanity at the exact moment the crime was committed. The court notes that there was no evidence presented by the accused to contradict the allegation that he killed his wife.

2. The appeal is partly meritorious.

3. Insanity is not considered as an exempting circumstance in this case.

4. The defense of insanity was not proven by the accused at the time of the commission of the crime. Insanity must have existed at the time of the offense or the accused must have been deranged even before the commission of the offense. The evidence must refer to the period preceding the act under prosecution or to the very moment of its execution. In this case, the testimony of the psychiatrist who examined the accused only came six months after the commission of the crime, and her conclusion was not definite and only an opinion. The defense failed to show clear and convincing proof that the accused had already been completely deprived of reason when he committed the crime.

5. The trial court erred in imposing the death penalty on the accused without considering the presence or absence of aggravating and mitigating circumstances. The proper penalty to be imposed on the accused, who was convicted of the complex crime of parricide with unintentional abortion, should be that for the graver offense which is parricide. The law on parricide is punishable with reclusion perpetua to death, and the court should have determined whether there were aggravating or mitigating circumstances present before imposing the penalty.

6. Yes, the penalty for the crime of parricide should be reduced to reclusion perpetua due to the absence of aggravating or mitigating circumstances.

PRINCIPLES:

• Insanity as an exempting circumstance presupposes that the accused was completely deprived of reason or discernment and freedom of will at the time of the commission of the crime.

• The burden of proving the defense of insanity lies with the accused.

• In the absence of proof to the contrary, every person is presumed to be of sound mind.

• Insanity must be proven at the very moment when the crime was committed.

• The presumption of law always lies in favor of sanity.

• Domestic altercation preceding the crime indicates that the accused was aware of the nature of his actions.

• The behavior of the accused after the commission of the crime may indicate repentance and awareness of the wrongfulness of his act.

• Insanity must have existed at the time of the commission of the offense or the accused must have been deranged even prior thereto. The inquiry into the mental state of the accused should relate to the period immediately before or at the precise moment of doing the act subject of the inquiry.

• When insanity is alleged as a ground for exemption from criminal responsibility, the evidence must refer to the time preceding the act under prosecution or to the very moment of its execution. If the evidence points to insanity subsequent to the commission of the crime, the accused cannot be acquitted.

• The defense of insanity is a defense in the nature of a confession or avoidance, and clear and convincing proof is required to establish its existence.

• In imposing penalties, the court should consider the presence or absence of aggravating and mitigating circumstances. When a single act constitutes two or more grave or less grave felonies, the penalty for the most serious crime shall be imposed, taking into account the aggravating and mitigating circumstances.

• When a penalty prescribed by law consists of two indivisible penalties, and there are neither mitigating nor aggravating circumstances, the lower penalty shall be imposed.

• The crime of parricide is not always punishable with death, as it is not a capital crime per se. The law provides for the flexible penalty of reclusion perpetua to death, depending on the presence or absence of mitigating and aggravating circumstances.