Facts:
Evaristo Vaquilar was found guilty of
killing his wife and his daughter, as well as injuring other persons with a
bolo. Eyewitnesses testified that the defendant appeared to be insane
prior to the commission of the crimes. They also testified that the
appellant was complaining of pains in his head and stomach prior to the
killing. The witnesses’ evidence for insanity include:
•
“appellants eyes were very big and red with his sight penetrating at the time
he was killing his wife.”
•
“he looked at me he was crazy because if he was not, he wouldn’t have killed
his family”
•
at the moment of cutting those people, “he looked like a madman; crazy because
he would cut anybody at random”
•
sister said, “…then he pursued me….he must have been crazy because he cut me”
Issue:
Whether or not these pieces of
evidence are sufficient to declare the accused as insane, therefore exempt from
criminal liability.
Held:
The evidence is insufficient to declare
him insane. The appellant’s conduct was consistent with the acts of an
enraged criminal, not of a person with an unsound mind at the time he committed
the crimes. The fact that a person acts crazy is not conclusive that he is
insane. The popular meaning of “crazy” is not synonymous with the
legal terms “insane”. The conduct of the appellant after he was confined
in jail is not inconsistent with the actions of a sane person (not saying a
word in the cell, crying out loud at night) who has reflected and felt remorse
after the commission of the crime.
The court further held that mere mental
depravity, or moral insanity which results not from any disease of the mind,
but from a perverted condition of the moral system where the person is
mentally sane, does not exempt one from criminal responsibility. In the
absence of proof that the defendant had lost his reason or became demented
after a few moments prior to or during the perpetration of the crime, it is
presumed that he was in a normal state of mind
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