MANILA, Philippines — The Supreme Court (SC) has ruled that a documented history of mental illness is not necessary for an accused to invoke legal insanity as a defense, as long as there is sufficient evidence proving a loss of intelligence at the time of the crime.

In a decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division acquitted a woman charged with homicide and ordered her confinement at the National Center for Mental Health (NCMH) for treatment.

The accused was charged after her father found her naked, covered in blood, and chanting religious phrases over her best friend’s body. 

She claimed she attacked the victim after seeing her grow horns and transform into a demon. She also said she heard the Virgin Mary instruct her to place a cross into the victim’s heart.

The SC ruled that the accused provided sufficient proof of insanity at the time of the crime.

 It clarified that legal insanity is established when a person is deprived of intelligence before, during, or immediately after committing an act, regardless of whether they have prior medical records.

While documented psychiatric history can support an insanity plea, the SC emphasized that it is not a requirement. 

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

The Supreme Court also recognized the disadvantage faced by marginalized individuals who lack access to psychiatric care, stressing that all legal defenses should be equally accessible regardless of one’s financial situation.  

“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,” it said.  

Although the accused was spared from imprisonment, the SC ordered her confinement at the National Center for Mental Health (NCMH) for thorough evaluation and treatment.  

Her release will only be allowed upon the recommendation of her attending physician and with approval from the Regional Trial Court (RTC).