The Supreme Court Third Division has acquitted a mother diagnosed with schizophrenia who had been convicted of parricide over the death of her five-year-old daughter.
In a decision penned by Associate Justice Samuel Gaerlan, the Court granted the mother’s appeal and overturned her conviction, ruling that she was exempt from criminal liability on the ground of legal insanity due to schizophrenia.
The case stemmed from an incident in which the accused jumped off a bridge into a river while carrying her daughter. The mother survived after being rescued by a man aboard a styrofoam banca, while the child’s lifeless body was found in the same river the following day.
The Regional Trial Court (RTC) earlier ruled that the mother intended to harm her daughter when she jumped off the bridge while embracing the child. She was convicted of parricide and sentenced to reclusion perpetua, or up to 40 years in prison.
On appeal, the mother argued that she was not in her right mind at the time of the incident and had no memory of what happened. She said she could only recall walking with her daughter and later regaining consciousness while floating in the water. The Court of Appeals, however, affirmed the RTC ruling.
A licensed physician from the National Center for Mental Health testified that the mother had been diagnosed with schizophrenia.
The Supreme Court disagreed with the lower courts and held that the mother was able to medically establish that she was suffering from schizophrenia at the time of the incident. The Court relied on the testimony and mental status examination reports of psychiatrists who evaluated her condition.
Under Article 12 of the Revised Penal Code, insanity is among the circumstances that exempt a person from criminal liability. It is defined as a disease or defect of the brain manifested through language or conduct that deprives a person of reason or discernment.
Despite clearing her of criminal liability, the Supreme Court held the mother civilly liable and ordered her to pay the victim’s heirs P75,000 in civil indemnity and P200,000 in moral, exemplary, and temperate damages.
The Court also ordered her immediate transfer from the Correctional Institution for Women to the National Center for Mental Health for treatment. She may only be released upon order of the RTC, based on the recommendation of her attending physician.