People vs. Dungo 199 SCRA 860

Rosalino Dungo stabbed Mrs. Sigua, with a knife from the envelope he was carrying, inside the field office of the Department of Agrarian Reform. Mrs. Sigua died and an information for murder was filed against Dungo. The accused raised the defense of insanity. During the trial, the prosecution presented the victim’s husband, Atty. Sigua, to testify that the accused visited their house to confront him on why his wife was making it difficult for the accused to transfer the landholding his father to him. The trial court convicted him because the act of concealing a fatal weapon and the act of taking flight in order to evade arrest indicates that accused was sane during the time he committed the stabbing.

The case went up to the Supreme Court for automatic review.


Issue: Whether it is permissible to receive evidence of the accused’s mental condition for a reasonable period both before and after the time of the act in question. 

Ruling:

Yes. The Court held that “Evidence of insanity must have reference to the mental condition of the person whose sanity is in issue, at the very time of doing the act which is the subject of inquiry. However, it is permissible to receive evidence of his mental condition for a reasonable period both before and after the time of the act in question. Direct testimony is not required nor the specific acts of derangement essential to establish insanity as a defense.”