US v. Vaquilar
Art. 38, Civil Code. Minority, insanity or imbecility, the state of being a deaf-mute, prodigality and civil interdiction are mere restrictions on capacity to act, and do not exempt the incapacitated person from certain obligations, as when the latter arise from his acts or from property relations, such as easements.
Appellant killed his wife and daughter while wounding others with a bolo. Witnesses testify that he seemed insane during and after the commission of the crimes:
- There was no known disagreement between the family members of the appellant prior to the event.
- Appellant looked like a mad man; crazy because he would cut everybody at random without paying attention to who it was.
- He was quiet during his time in prison and cried out every other night, “What kind of people are you to me, what are you doing to me, you are beasts.”
Confronted with the issue of whether or not the Vaquilar was mentally deranged during the commission of the crime, the Supreme Court ruled in the negative.
“There is a vast difference between an insane person and one who has worked himself up into such a frenzy of anger that he fails to use reason or good judgment in what he does. Being crazy is a state wherein a person is merely acting out of the ordinary whereas being insane means acting with an unsound, perhaps diseased, mind. Not applying restraint to anger or passion makes the appellant criminally liable. The testimonies do not prove insanity, they merely point to hysteric acts.”
Further, in People v. Mortimer, the SC distinguished passion and insanity as follows:
“Passion and insanity are very different things, and whatever indulgence the law may extend to person under provocation, it does not treat them as freed from criminal responsibility.”
In People v. Foy, the court said:
“The heat of passion and feeling produced by motives of anger, hatred, or revenge, is not insanity.”
