People vs. Tibon Case Digest G.R. No. 188320, June 29, 2010

Facts:
Honorio Tibon (accused-appellant) and his common-law wife Gina Sumingot (Gina) lived together as husband and wife. They had two children, Keen Gist (KenKen) and Reguel Albert (Reguel). They lived together with Tibon’s parents and siblings on the third floor of a rented house. Gina went to Hongkong to work as a domestic helper, leaving their children to Tibon’s custody. After some time, Tibon heard from her sister who was also working abroad that Gina was having an affair with another man. After the revelation, he was spotted drinking a lot and was seen hitting his two children.

On the night of December 12, 1998, at around 11:30 p.m., accused-appellant’s mother and his siblings (Zernan and Leilani), went to Tibon’s room. They saw him with the two children who appeared to be lifeless and bore wounds on their bodies. When Tibon realized that his mother and siblings had seen the children lying on the floor he stabbed himself on the chest with a kitchen knife and jumped out of the window of their house. At the hospital, accused-appellant survived and was treated however, the children could no longer be revived.

When Gina heard about the incident, she went home immediately and confronted Tibon at the hospital where he was confined. He confessed to stabbing their children and begged her for forgiveness.

In court, Tibon denied the charges against him and raised insanity as defense. He said that he could not recall what happened on the night he allegedly stabbed his two children. He also could not remember being taken to the hospital. He said that he was only informed by his siblings that he had killed his two children, causing him to jump off the window of their house.

Issue:
Whether or not the exempting circumstance of insanity applies to the accused-appellant’s case?

Ruling:
No.  Under Article 12 of the RPC “An imbecile or an insane person, unless the latter has acted during a lucid interval” is exempted from criminal liability. Anyone who pleads the exempting circumstance of insanity bears the burden of proving it with clear and convincing evidence. Testimony or proof of insanity must relate to the time immediately preceding or coetaneous with the commission of the offense.

The medical records of Tibon with the National Center for Mental Health (NCMH) is inapplicable for such refers to his condition to stand trial and not to his mental state immediately before or during the commission of the crimes.

Tibon’s behavior was triggered by jealousy because of the revelation that his wife was having an affair overseas. Uncontrolled jealousy and anger are not equivalent to insanity.

The court considered Parricide as the applicable law in this case. Under Article 264 Parricide is committed when: (i) a person is killed; (ii) the deceased is killed by the accused; (iii) the deceased is the father, mother, or child, whether legitimate or illegitimate, or a legitimate other ascendant or other descendant, or the legitimate spouse of the accused. Tibon was found guilty by this Court with the punishment of reclusion perpetua.