G.R. No. 186533 - PEOPLE OF THE PHILIPPINES, VS. EFREN CASTILLO, ACCUSED-. D E C I S I O N - Supreme Court E-Library

Ruling

Accordingly, it is competent for the ordinary witness to give his opinion as to the sanity or mental condition of a person, provided the witness has had sufficient opportunity to observe the speech, manner, habits, and conduct of the person in question . Commonly, it is required that the witness details the factors and reasons upon which he bases his opinion before he can testify as to what it is. As the Supreme Court of Vermont said: "A non-expert witness may give his opinion as to the sanity or insanity of another, when based upon conversations or dealings which he has had with such person, or upon his appearance, or upon any fact bearing upon his mental condition, with the witness' own knowledge and observation, he having first testified to such conversations, dealings, appearance or other observed facts, as the basis for his opinion." [35] The mother of an offended party in a rape case, though not a psychiatrist, if she knows the physical and mental condition of the party, how she was born, what she is suffering from, and what her attainments are, is competent to testify on the matter. [36] Thus, even though the Guidance Psychologist who examined AAA may not qualify as an expert witness, though the psychological tests conducted by her on AAA may not be accurate to determine AAA's mental capacity, such circumstance is not fatal to the prosecution's cause. In the case at bench, BBB testified that AAA has been suffering from epilepsy since she was nine years old, which is one of the reasons why AAA was not able to finish her Grade I level. AAA also had to stop schooling because she had difficulties understanding her lessons in school, she cannot write well, she had poor memory and she had difficulty answering even the simplest question asked of her. BBB further stated that AAA is the eldest of her four children; however, compared to her younger siblings, AAA had a hard time comprehending the instructions given to her at home and in school. In the same way, though the Guidance Psychologist who examined AAA may not be qualified as an expert witness, her observations, however, as regards the appearance, manner, habits and behavior of AAA, is also admissible in evidence as an ordinary witness' testimony. Even before the Guidance Psychologist administered the psychological tests on AAA, she already noticed that AAA lacked personal hygiene. While conversing with AAA, she observed that AAA has low level mental functioning as she has difficulty understanding simple things, has a vague concept of big numbers and time †like days of the week, and has regressed behavior that is not congruent to her age, i.e. , 21 years old at the time of her examination. She also stated that she was not able to administer the Purdue Non-Language Test , which is an Intelligence Quotient Test , on AAA due to the latter's inability to identify the items therein. This Court, in People v. Dalandas , clarified that a mental retardate, in general, exhibits a slow rate of matura