BATANGAS STATE UNIVERSITY
HUMAN BEHAVIOR AND VICTIMOLOGY
Project: Research on Insanity Defense in the Philippines (Case
Digest)
Name of Student: DE LA ROSA, RHEA T.
Instructor: DR. Fredda H. Ebanada
Case Title: People of the Philippines vs. Policarpio Rafanan,
G.R. No. L-54135
Date of Promulgation: November 21, 1991
FACTS:
The accused, Policarpio Rafanan Jr. is living with his mother Ines
Rafanan alias ‘Baket Ines’ together with his wife and two childen in
Barangay San Nicholas, Villasis, Pangasinan. On February 27, 1976,
complainant Estelita Ronaya was only fourteen years old when she was
hired as a househelper by the mother of the accused with the salary of
P30.00 a month. In the evening of March 16, 1976, after dinner Ines
Rafanan sent Estelita Ronaya in their store which was located in about
six (6) meters away in front of their house for help where the accussed
was inside the store. On or about 11 o’clock in the evening, the
complainant was called by the accussed to help him close the door of
the store and Estelita Ronaya complied. The accussed pulled the
complainant inside the store and forced her to have a sexual
intercourse theathening her using a bolo on her neck while Estelita
Ronaya struggled and cried. Then, she was forced to lie down and the
accused succeeded having carnal knowledge of the complinant. After
the rape, Policarpio Rafanan theathened to kill Estelita Ronaya to not
report the matter to her mother or to anybody in the house. On March
17, 1976, in the evening, the complainant left the house of the
Rafanan upon the knowing of his family about the incident. On March
18, 1976, Estelita Ronaya told her mother Alejandra Ronaya that she
was raped by the accused that leads to the arrest and conviction of the
appellant of the crime of rape.
Policarpio Rafanan filed an appeal and invoked that he is
suffering from mental abberation charactherized as schizophrenia on
the commission of the crime. The trial was suspended and the
appellant was confined in the National Mental Hospital in Mandaluyong
City for observations and treatments. On December 29, 1976,
Policarpio Rafanan was admitted to the hospital and stayed there until
June 26, 1978. During his confinement, four (4) clinical reports on his
mental and physical assesment was respectively prepared by Dr.
Simplicio N. Masikip and Dr. Arturo R. Nerit, physician-in-charge and
Chief of Forensic Psychiatry Service. When the appellant was deemed
to be in a better condition and can stand trial mentally and physically
the trial of the case was resumed. Appelant’s plea of insanity in the
form of schizopherenia as a mental disorder. The Trial Court ruled
against Policarpio Rafanan and sentenced to Reclusion Perpetua and to
indemnify the complainant in the total amount of P10,000.00 by way of
moral damage and to pay the costs. The Supreme Court rejected the
insanity defense filed by the appellant.
ISSUE:
Whether or not the appellant should be exempted from the crime
of rape on the grounds of insanity due to schizophrenia.
RULING:
The Supreme Court rejected the insanity defense of the appellant
and the decision appealed from is affirmed with the excemption that
the amount of the moral damages is raised to P30,000.00 costs against
Policarpio Rafanan. The imbecility was not proven clearly which in this
case the appellant failed to present a convincing and clear evidence
regarding on his mental state at the time on before and during the
commission of the crime.
In addition there are two test in order to prove insanity on the
required standards of legal insanity:
a. The test of cognition – complete deprivation of intelligence;
b. The test of volition – total deprivation of freedom of the will.
Philippine case law relies on the test of cognition.
In this case, the appellant is suffering from schizophrenia which
is a chronic mental disorder. This case falls under the Cognitive
Perspective where the factors that affect the occurence or causing this
mental disorder is the person’s cognition, thoughts and beliefs. The
person with this disorder detatched themselves from the reality with
the delusions, hallucinations, disorganized thinking and speech,
disorganized motor behavior and negative symptopms. According to
the clinical reports of the appellant that he heard some strange voices
and sounds, he mumble alone by himself and he has lack of insight.
Policarpio Rafanan is clearly not deprived of the consiousness of his
acts at the time of the commission of the crime according to Dr.
Jovellano during his cross examination. Therefore, the court denied and
ruled the appellant as he had failed to completely prove the
impairment of his mental faculties.
Policarpio Rafanan should have been admitted with mitigating
circumstance although it is contradictory to his case and sentence
(Reclusion Perpetua). In Article 63 of the Revisd Penal Code states that
in crimes which the law prescribes a single indivisible penalty and
imposed, this penalty must be applied regardless of any mitigating or
aggravating circumstances.
Annotated Bibliography
“People of the Philippines vs. Policarpio Rafanan G.R. No. L-54135”.
The LAWPHiL Project, ARELLANO LAW FOVNDATION, PHILIPPINE
LAWS AND JURISPRUDENCE DATABANK, n.d. Web. 06 May 2021.
https://lawphil.net/judjuris/juri1991/nov1991/gr_l_54135_1991.ht
ml#fnt.
In this website, the case of rape had delivered
justice to the compalinant. Analyzing the appellant’s condition in
the time when the crime transpired. As shown in the presented
reports, that the appellant had this mental disorder characterized
as schizoprenia. However, the court is not convinced for lack of
sufficient evidence. Cognitive Disorder includes delusion which
are not real or false ideas that cannot be corrected by reasoning
and it is not part of a person cultural environment. Delusion is
one of the common symptoms of schizoprenia which for this type
of disorder many suffer from delusional fantasies about the
destruction of the world.
Teodosio, R. (n.d.) “People of the Philippines vs. Policarpio Rafanan
G.R. No. L-54135, 1991-11-21”, Lawyerly. Web. 06 May 2021.
https://lawyerly.ph/digest/c9cea?user=7351
Ramil Aguilar Teodosio indicated the concised and
chronologically arrange facts in the case digest. The author
concluded the principles of the imbecility or insanity of the
appellant on the time of the commission of the crime. The person
who is mentally impaired should be absolutely deprive a person
of intelligence. The mental faculties does not exclude
imputability.
Octavo, T. (2020) Case Digest: People of the Philippines vs. Policarpio
Rafanan G.R. No. L-54135, November 21, 1991. Legally FILIPINA.
September 30, 2020. Web. 06 May 2021.
https://lexphil.blogspot.com/2014/03/people-v-rafanan-204-scra-
65.html?m=1
Thea Octavo clearly explained the case of Rafanan has
rejected of plea of insanity under Article 12 of the Revised Penal
Code of the Philippines. The absence of clear and convincing
evidence which proves that the appellant is insane on the time
he committed such act made the court to deny the plea.
Cruz, M. (2014) People v. Rafanan, 204 SCRA 65, Law School Notes
and Digest, March 22, 2014. Web. 06 May 2021.
https://lexphil.blogspot.com/2014/03/people-v-rafanan-204-scra-
65.html?m=1
Michelle Vale Cruz draw on his case digest as to the
insanity defense of the appellant that held to be denied for
unclear evidences of the appelant to be mentally impaired.
