People of the Philippines vs. Reynaldo Villanueva y Marquez G.R. No.

172697 September 25, 2007 Facts: On January 21, 2000, upon going home, appellant Reynaldo Villanueva, brought hotdogs that he cooked since he was hungry. When his mother asked if she could have some, appellant got irked because he did not have breakfast and lunch. His mother got scared of him and ran away. Appellant was so peeved that he wanted to give vent to his anger. After finishing his food, he went to his mothers room. It was this point that the appellant committed the crimes. Appellant killed his niece Angelica Villanueva by boxing her on the head and kicking her several times on the different parts of her body, which cause her death. Appellant also mauled his nephews Rexie and Enrique Villanueva. Consequently, appellant was charged with murder, frustrated murder and attempted murder by the trial court. Appellant pleaded insanity. Issue: Whether or not the defense of insanity can exempt the accused of criminal liability.

Ruling: No. The supreme court held that proof of existence of some abnormalities in the mental faculties will not exempt the accused from culpability, if it was shown that he was not completely deprived of freedom and intelligent. Appellants recollection of the events prior to the crimes and his emotions afterwards indicate that he was sane before, during and after the commission of the crimes. The report also states that appellant felt guilty about Angelicas death and apprehensive of being I jail for longer time. A feeling of remorse is inconsistent with insanity, as it clear indication that he was conscious of his act.