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People vs.

March 31, 1933 (58 Phil 255)
Plaintiff and appellee: People of the Philippines
Defendants and appellant: Potenciano Taneo

On January 16, 1932, in the house of Potenciano Taneo’s parents in Dolores, Ormoc, Leyte, because of
severe stomachache, Potenciano slept early. While sleeping, he suddenly got up, left the room with a
bolo in hand and upon meeting his wife who tried stop him, he wounded her int eh abdomen. Several
others were also attacked, this includes his father, and his guests, Fred Tanner and Luis Malinao. It was
claimed that he was dreaming when the crime happened. The trial court found Potenciano guilty of
parricide and was sentenced to reclusion perpetua.

ISSUE: WON the defendant is criminally liable.

HELD: No. The defendant acted while in a dream and his acts with which he was charged were not
voluntary in the sense of entailing criminal liability. The expert witness claimed that the defendant was
under the influence of hallucination and not in his right mind. The defendant is not criminally liable
however, he was ordered to be confined in an insane asylum.

L-45130 | February 17, 1937 | J. Laurel
Celestino Bonoan is charged with the crime of murder for stabbing Carlos Guison
with a knife, which caused his death three days afterwards. An arraignment was
then called, but the defense objected on the ground that the defendant was
mentally deranged and was at the time confined at the Psychopatic Hospital. After
several months of summons for doctors, production of the defendant’s complete
record of mental condition from the hospital and defendant’s admission to the
hospital for personal observation, assistant alienist Dr. Jose Fernandez finally
reported to the court that Bonoan may be discharged for being a “recovered case”.
After trial, the lower court found Bonoan guilty and sentenced him to life

1987. She got . Pampanga. a symptom leading to dementia praecox. she noticed her husband to be in deep thought always. He was confined for one week at the Macabali Clinic. carrying a bloodied bladed weapon. After a brief talk. plaintiff-appellee. When Andrea followed him to the store. 1987 between 2:00 and 3:00pm. maltreating their children when he was not used to it before. he underwent medical treatment. This ruling was based on the following evidence: Uncontradicted evidence that accused was confined in the insane department of San Lazaro Hospital and diagnosed with dementia praecox long before the commission of the offense and recurrence of ailments were not entirely lacking of scientific foundation Persons with dementia praecox are disqualified from legal responsibility because they have no control of their acts. the accused drew a knife from the envelope he was carrying and stabbed Mrs. The accused. Later. The defense first presented the testimony of Andrea Dungo.The defense now appeals. The autopsy report revealed that the victim sustained 14 wounds. in defense of him. Apalit. that the defense did not establish the defendant’s insanity and finding accused guilty. tried to show that he was insane at the time of the commission of the offense. claiming the lower court made errors in finding Bonoan suffered dementia only occasionally and intermittently. indicating the police’s doubt of his mental normalcy Defendant suffered from manic depressive psychosis according to Dr. Joson PEOPLE OF THE PHILIPPINES. Thereafter he had his monthly check-up. and orders for his confinement in San Lazaro Hospital or other hospital for the insane. her husband had been engaged in farming up to 1982 when he went to Lebanon for six (6) months. FACTS On March 16. Her husband did not finish his two-year contract because he got sick. Upon his arrival. did not show any kind of abnormality. Francisco Accused was sent the Psychopatic hospital on the same day of crime and arrest. 5 of which were fatal. After which he departed from the office with blood stained clothes. in December 1983. he was not able to resume his farming. The Court finds the accused demented at the time he perpetrated the crime. dementia praecox symptoms similar to manic depression psychosis Accused had an insomnia attack. Thereafter. the accused went to Mrs. demanding another payment from his customers even if the latter had paid. Two weeks prior to March 16. he went back to the store. chasing any child when their children quarreled with other children. Because of his sickness. Sigua's office at the Department of Agrarian Reform. which consequently exempts him from criminal liability. Sigua several times. accused-appellant. vs. the wife of the accused. her husband again left for Saudi Arabia and worked as welder. four days prior to act according to Dr. ROSALINO DUNGO. Issue: W/N the lower court erred in finding the accused guilty Held: Yes. According to her. he was no longer there.

In order that insanity may relieve a person from criminal responsibility. (People v. . his free agency being at the time destroyed. Sylvia Santiago and Dr. The testimony on the statements of her husband was corroborated by their neighbor Thelma Santos who heard their conversation. that the accused be deprived of cognition. that is. it is necessary that there be a complete deprivation of intelligence in committing the act. it is necessary that there be a complete deprivation of intelligence in committing the act. Under the right and wrong test. during and after the commission of the alleged crime and that his insanity was classified under organic mental disorder secondary to cerebro-vascular accident or stroke. Under foreign jurisdiction. ISSUE Whether or not the accused was insane during the commission of the crime charged.worried as he was not in his proper mind. as per order of the trial court dated August 17. 1987. She looked for him. Dra. She returned home only when she was informed that her husband had arrived. that he acts without the least discernment. For insanity to relieve the person of criminal liability. the barangay official did not bother to get the wallet from him. A person acts under an irresistible impulse when. 105 SCRA 151) It is difficult to distinguish sanity from insanity. "here is my wallet. One who suffers from insanity at the time of the commission of the offense charged cannot in a legal sense entertain a criminal intent and cannot be held criminally responsible for his acts. a person is insane when he suffers from such perverted condition of the mental and moral faculties as to render him incapable of distinguishing between right and wrong. That same day the accused went to Manila. namely: delusion test. Under the delusion test. she heard from people the words "mesaksak" and "menaksak" (translated as "stabbing" and "has stabbed"). She saw her husband in her parents-in-law's house with people milling around. an insane person believes in a state of things. "That is the only cure for my ailment. they concluded that Rosalino Dungo was psychotic or insane long before. there are three major criteria in determining the existence of insanity. her husband exclaimed. and that he chose to live longer even in jail. I have a cancer in my heart. you surrender me. Insane delusion is manifested by a false belief for which there is no reasonable basis and which would be incredible under the given circumstances to the same person if he is of compos mentis. that there is complete absence or deprivation of the freedom of the will. by reason of duress or mental disease. She instinctively asked her husband why he did such act. including the barangay officials. he has lost the power to choose between right and wrong. Based on the reports of their staff. While on her way home." However. on August 25. to avoid the act in question. but he replied." Her husband further said that if he would not be able to kill the victim in a number of days. Puno. RULING No. that he acts without or the least discernment and that there be complete absence or deprivation of the freedom of the will. Nicanor Echavez of the National Center for Mental Health testified that the accused was confined in the mental hospital. His unlawful act is the product of a mental disease or a mental defect. There is no definite defined border between sanity and insanity. 1987. Turning to the barangay official. and the right and wrong test. the existence of which no rational person would believe. he would die. irresistible impulse test.

it states that insanity is evinced by a deranged and perverted condition of the mental faculties. Without positive evidence that the defendant had previously lost his reason or was demented. This also established that the accused has lucid intervals. It is not usual for an insane person to confront a specified person who may have wronged him. When the complainant went near him. People of the Philippines vs. the accused emerged from where he was hiding and stabbed Patrimonio. indicate that he was conscious and knew the consequences of his acts in stabbing the victim. Sigua. 19. Trial court suspended the tria. it is also permissible to receive evidence of his mental condition for a reasonable period before and after the time of the act in question. One evening. 204 SCRA 65 FACTS: Complainant Estelita Ronaya was only 14 years old when hired as a househelper by the mother of the accused. who was lying on a bench. Samar. Anacito Opuran. However. Echavez testified to the effect that the appellant could have been aware of the nature of his act at the time he committed it when he shouted (during laboratory examination) that he killed Mrs. Sigua. Rafanan. Trial of case resumed. At 7:45 pm of the same day. that he fled to Manila to evade arrest. it can be inferred that the accused was aware of his acts. People v. The vagaries of the mind can only be known by outward acts. he was reported to be behaved and in improved condition and in mental condition to stand court in trial. An insane person has no full and clear understanding of the nature and consequence of his act. However. that he ran away from the scene of the incident after he stabbed the victim several times. which is manifested in language or conduct. After 2 years. After that. The allegation of insanity or imbecility must be clearly proved. The accused Policarpio Rafaran and his family lived with his mother in the same house. 6:30 pm at Catbalogan. the accused was able to Mrs. Moreover. the definition of insanity under Sec 1039 of the Revised Administrative Code can be applied. the mother of the accused called complainant to help him close the door. The fact that the accused was carrying an envelope where he hid the fatal weapon. But in the case at hand. The next day. there's no definite test or criterion for insanity. From this. it will be presumed that he was in a normal condition. he warned the complainant not to tell anyone about it or he will kill her. Samar. herein accused. Appellant claimed that he is suffering from schizophrenia when he inflicted violent intentions to Estelita. In essence. and ordered his confinement to National Mental Hospital in Mandaluyong.Under Philippine jurisdiction. This statement makes it highly doubtful that the accused was insane when he committed the act. 1998. stabbed Allan Dacles. a few moments prior to or during the perpetration of the crime. the family of the accused knew what happened. Anacito Opuran FACTS: On Nov. ISSUE: W/N the reason of insanity is sufficient to relieve him from criminal liability HELD: No. Thereafter. Dr. . Evidence of insanity must refer to the mental condition at the very time of doing the act. Policarpio was married and has children. he pulled her inside the store and raped her despite her resistance. Demetrio Patrimonio was walking on the national highway of Catbalogan.

Battered women . Testimonies of two expert witnesses on the “battered woman syndrome”. and finally. alleged that the cause of death of the victim was by beating through the use of a lead pipe. she consulted medical doctors who testified during the trial. Appellant admitted having killed the victim with the use of a gun. insanity is not attendant in the case at bar. appellant filed an URGENT OMNIBUS MOTION praying that the Honorable Court allow (1) the exhumation of Ben Genosa and the re-examination of the cause of his death. The Supreme Court partly granted the URGENT OMNIBUS MOTION of the appellant. After trial. Pajarillo. Dra.ISSUE: Whether or not accused can use the exempting circumstance of insanity as a defense. However. Appellant testified that every time her husband came home drunk. however. Marivic and Ben lived happily but apparently thereafter. A battered woman has been defined as a woman “who is repeatedly subjected to any forceful physical or psychological behavior by a man in order to coerce her to do something he wants her to do without concern for her rights. 2. by his wife Marivic Genosa. a partial re-opening of the case a quo to take the testimony of said psychologists and psychiatrists. Insanity must exist immediately before or at the précised moment of the commission of the act. People of the Philippines vs. During their first year of marriage. were presented and admitted by the trial court and subsequently submitted to the Supreme Court as part of the records. The accused failed to prove that he was insane at the precise moment of commission or immediately before said act. The Court ruled in the negative as appellant failed to prove that she is afflicted with the “battered woman syndrome”. Dayan and Dr. in the alternative. Appellant invoked self defense and defense of her unborn child. Thus. he would provoke her and sometimes beat her. appellant and the victim were quarreled and the victim beat the appellant. It remanded the case to the trial court for reception of expert psychological and/or psychiatric opinion on the “battered woman syndrome” plea. Ruling: 1. The information for parricide against appellant. Whether or not treachery attended the killing of Ben Genosa. Marivic Genosa FACTS: This case stemmed from the killing of Ben Genosa. Whether or not appellant herein can validly invoke the “battered woman syndrome” as constituting self defense. Ben changed and the couple would always quarrel and sometimes their quarrels became violent. On automatic review before the Supreme Court. RULING: No. (2) the examination of Marivic Genosa by qualified psychologists and psychiatrists to determine her state of mind at the time she killed her husband. the Regional Trial Court found appellant guilty beyond reasonable doubt of the crime of parricide with an aggravating circumstance of treachery and imposed the penalty of death. ISSUE: 1. Whenever beaten by her husband. On the night of the killing. appellant herein. appellant was able to run to another room. (3) the inclusion of the said experts’ reports in the records of the case for purposes of the automatic review or.

loving (or. at least.” which has three phases: (1) the tension-building phase.grave harm to the accused. however. and (3) the tranquil. Neither did appellant proffer sufficient evidence in regard to the third phase of the cycle. is not discounting the possibility of self-defense arising from the battered woman syndrome. the existence of the syndrome in a relationship does not in itself establish the legal right of the woman to kill her abusive partner. The defense fell short of proving all three phases of the “cycle of violence” supposedly characterizing the relationship of Ben and Marivic Genosa. not merely imaginary. No doubt there were acute battering incidents but appellant failed to prove that in at least another battering episode in the past.not necessarily immediate and actual -. and (3) Lack of sufficient provocation on the part of the person defending himself. In any event. he apparently ceased his attack and went to bed. Under the existing facts of the present case. He was no longer in a position that presented an actual threat on her life or safety. Unlawful aggression is the most essential element of self-defense. Third. Evidence must still be considered in the context of self-defense. Taken altogether. not all of these elements were duly established. the batterer must have posed probable -. The reality or even the imminence of the danger he posed had ended altogether.on the life or safety of a person.include wives or women in any form of intimate relationship with men. In the present case. in order to be classified as a battered woman. at the time of the killing. the couple must go through the battering cycle at least twice. The Court. there was a sufficient time interval between the unlawful aggression of Ben and her fatal attack upon him. During that time. . Furthermore. and she remains in the situation. If it occurs a second time. the final acute battering episode preceding the killing of the batterer must have produced in the battered person’s mind an actual fear of an imminent harm from her batterer and an honest belief that she needed to use force in order to save her life. based on the history of violence perpetrated by the former against the latter. she is defined as a battered woman. Settled in our jurisprudence. according to the testimony of Marivic herself. is the rule that the one who resorts to self-defense must face a real threat on one’s life. each of the phases of the cycle of violence must be proven to have characterized at least two battering episodes between the appellant and her intimate partner. the Revised Penal Code provides that the following requisites of self-defense must concur: (1) Unlawful aggression. these circumstances could satisfy the requisites of self-defense.” More graphically. sudden and unexpected attack -. It presupposes actual. Second. however. however. and the peril sought to be avoided must be imminent and actual. nonviolent) phase.or an imminent danger thereof -. (2) Reasonable necessity of the means employed to prevent or repel it. (2) the acute battering incident. Thus. Any woman may find herself in an abusive relationship with a man once. the battered woman syndrome is characterized by the so-called “cycle of violence. she had gone through a similar pattern. First. She had already been able to withdraw from his violent behavior and escape to their children’s bedroom.

The first circumstance arose from the cyclical nature and the severity of the battery inflicted by the batterer-spouse upon appellant. both unlawful and sufficient to produce such a condition of mind. which overcame her reason and impelled her to vindicate her life and that of her unborn child. 2. during which the accused might recover her normal equanimity. That is. NO. Besides. the following requisites should concur: (1) there is an act. and (2) this act is not far removed from the commission of the crime by a considerable length of time.The mitigating factors of psychological paralysis and passion and obfuscation were. Because of the gravity of the resulting offense. It should be clarified that these two circumstances -. in order to appreciate alevosia. which was analogous to an illness diminishing the exercise of her will power without depriving her of consciousness of her acts. considering the presence of two (2) mitigating circumstances and without any aggravating circumstance. to 14 years 8 months and 1 day of reclusion temporal as maximum. equally axiomatic is the rule that when a killing is preceded by an argument or a quarrel. The Supreme Court affirmed the conviction of appellant for parricide. To appreciate this circumstance. Inasmuch as appellant has been detained for more than the minimum penalty hereby imposed upon her. As to the extenuating circumstance of having acted upon an impulse so powerful as to have naturally produced passion and obfuscation. the repeated beatings over a period of time resulted in her psychological paralysis. treachery must be proved as conclusively as the killing itself. the director of the Bureau of Corrections may . because the deceased may be said to have been forewarned and to have anticipated aggression from the assailant. overwhelmed her and put her in the aforesaid emotional and mental state. The acute battering she suffered that fatal night in the hands of her batterer-spouse. Moreover. taken in favor of appellant.did not arise from the same set of facts. the penalty is reduced to six (6) years and one (1) day of prision mayor as minimum. However. in spite of the fact that she was eight (8) months pregnant with their child. treachery cannot be appreciated as a qualifying circumstance. it has been held that this state of mind is present when a crime is committed as a result of an uncontrollable burst of passion provoked by prior unjust or improper acts or by a legitimate stimulus so powerful as to overcome reason.psychological paralysis as well as passion and obfuscation -. however. the method of assault adopted by the aggressor must have been consciously and deliberately chosen for the specific purpose of accomplishing the unlawful act without risk from any defense that might be put up by the party attacked. The appellant acted upon an impulse so powerful as to have naturally produced passion or obfuscation.

This was duly proven by the certificate of live birth. Dr. 9344.A. Few minutes later. and by the testimony of his mother. 63 PHIL. in the resolution of the case. 9344) was enacted amending among others the age of criminal irresponsibility being raised from 9 to 15 years old. No. By virtue of R. Victim-survivors who are found by the courts to be suffering from battered women syndrome do not incur any criminal and civil liability nothwithstanding the absence of any of the elements for justifying circumstances of self-defense under the Revised Penal Code. he brought her to his house and placed her on the bed.A. He called on Adriano Comcom to help them. 9344) should be applied. where Comcom saw the body of a new born baby near a path adjoining the thicket where the appellant had gone a few moments before. R. Valentine Aguilar saw his neighbour. . he is exempted from criminal liability. Under R. at the time of the commission of the crime. He went along the plan and then he informed the Philippine Constabulary of all that had taken place and they discussed a plan to capture the opium owners. The case was pending when the Juvenile Justice and Welfare Act of 2006 (R. He was instructed to make sure that the shipment containing opium shall be unloaded in the country.immediately RELEASE her from custody upon due determination that she is eligible for parole. Emilio Nepomuceno declared that the appellant gave birth in her own house and brought her child into the thicket to kill it. 9344. the age of criminal irresponsibility has been raised from 9 to 15 years old. Petitioner was only 13 years old at the time of the commission of the alleged rape. Lua Chu and Uy Se Ting (1931) Facts: Samson was the chief of customs secret service in Cebu and Natividad was the former collector of customs. Furthermore.A. in order the better to assure the seizure of said opium and the arrest of its importers. 26 of said law provides that "xxx. Rushing to her aid. She claimed that it was hers. staggering and visibly showing of not being able to support herself. No. the accused already reached the age of majority. Held: The mere fact that the chief of customs secret service pretended to agree to a plan for smuggling illegally imported opium through the customhouse. by petitioner's own testimony. 9344) should be applied. Issue: Whether or not the Juvenile Justice and Welfare Act of 2006 (R. was below 15 years of age. Indubitably. petitioner’s age was never assailed in any of the proceedings before the RTC and the CA.A. Bandian emerged from the thicket with her clothes stained with blood both in the front and back. Josefina Bandian. At the time of the promulgation of judgment. unless she is being held for some other lawful cause. Sec. 530 FACTS: One morning. NOTE: After this case was decided by the Supreme Court. otherwise known as Anti-Violence Against Women and their Children Act of 2004 was enacted. Held: The Juvenile Justice and Welfare Act of 2006 (R. The trial court gave the credit to his opinion. People Facts: At the time of commission of rape. this law is evidently favorable to the accused. People v. petitioner.A.A. 9262. the accused was 13 years old while the victim was 6. PEOPLE v BANDIAN. got to a ticket apparently to respond to the call of" Ortega vs. is no bar to the prosecution and conviction of the accused.

or if she was. to be punishable. Bandian was not aware of their childbirth. she is acquitted of the crime that she had been accused of. . Infanticide and abandonment. with no fault or intention of causing it. must be committed wilfully or consciously. in causing her child‘s death in one way or another did so wilfully. conscious and free act or omission. She caused a wrong as that of giving birth to her child in the same place and later abandoning it not because of imprudence or any other reason that she was overcome by strong dizziness and extreme debility. consciously or imprudently. to take her child from the thicket to pee. it must be the result of voluntary. or at least. due to her debility or dizziness which cause may be considered as lawful or insuperable cause to constitute mitigating circumstances. The evidence does not show that the appellant. having the fourth and seventh exempting circumstances in her favour.Crime Committed: Infanticide and abandonment of a minorContention of the Accused: Apparently. she could not blame herself because it all happened by mere accident. it did not occur to her or she was unable. Bandian‘s act can be considered lawful or insuperable.HELD: Bandian is not guilty of infanticide. Thus.