People v. Rafanan, 204 SCRA 65

FACTS: Complainant Estelita Ronaya was only 14 years old when hired as a househelper by the mother of the accused. The accused Policarpio Rafaran and his family lived with his mother in the same house. Policarpio was married and has children. One evening, the mother of the accused called complainant to help him close the door. When the complainant went near him, he pulled her inside the store and raped her despite her resistance. After that, he warned the complainant not to tell anyone about it or he will kill her. The next day, the family of the accused knew what happened. Appellant claimed that he is suffering from schizophrenia when he inflicted violent intentions to Estelita. Trial court suspended the tria; and ordered his confinement to National Mental Hospital in Mandaluyong. After 2 years, he was reported to be behaved and in improved condition and in mental condition to stand court in trial. Trial of case resumed.

ISSUE: W/N the reason of insanity is sufficient to relieve him from criminal liability

HELD: No. The allegation of insanity or imbecility must be clearly proved. Without positive evidence that the defendant had previously lost his reason or was demented, a few moments prior to or during the perpetration of the crime, it will be presumed that he was in a normal condition.