
MANILA — The Supreme Court of the Philippines cleared a mother previously convicted of parricide in the death of her five-year-old daughter, ruling that her schizophrenia exempted her from criminal liability.
In a decision penned by Associate Justice Samuel H. Gaerlan, the court’s Third Division granted the woman’s appeal and reversed earlier rulings that found her guilty, citing legal insanity at the time of the incident.
The case stemmed from an episode in which the mother jumped from a bridge into a river while holding her child. A bystander aboard a makeshift banca managed to rescue the mother, but the child was not immediately found. The girl’s body was recovered the following day.
The mother maintained that she was not in her right state of mind, saying she could only recall walking with her daughter and had no memory of the घटना itself, adding that she regained awareness only while already in the water.
A physician from the National Center for Mental Health testified that the woman had been diagnosed with schizophrenia.
Despite this, the Regional Trial Court convicted her and imposed the penalty of reclusion perpetua, concluding that she intended to harm her daughter. The Court of Appeals later affirmed the conviction.
The Supreme Court, however, found that her mental condition at the time deprived her of the capacity to understand the nature and wrongfulness of her actions.
Under Article 12 of the Revised Penal Code, insanity is among the circumstances that exempt a person from criminal liability. The court cited the ruling in People v. Paña, which sets out the requirements to establish insanity: it must be present during the commission of the act, medically established, and must render the accused incapable of appreciating the act’s nature or wrongfulness.
The high court said these conditions were met, noting that psychiatric evaluations and testimony showed the mother was suffering from schizophrenia at the time. It described the disorder as a chronic condition that impairs a person’s ability to distinguish reality from fantasy, often accompanied by hallucinations and delusions.
Testimony in the case indicated that the mother exhibited paranoia and believed she was being threatened and talked about by others during the incident.
While the court ruled that she could not be held criminally liable, it ordered her to pay civil damages to the victim’s heirs, including P75,000 in civil indemnity and P200,000 covering moral, exemplary, and temperate damages.
The court also directed that she be transferred from the Correctional Institution for Women to the National Center for Mental Health for treatment. Her release will depend on an order from the trial court, based on the recommendation of her attending physician.





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