People vs Bonoan

THE PEOPLE OF THE PHILLIPINES, plaintiff-appellee vs.
CELESTINO BONOAN Y CRUZ, defendant-appellant.
Important provision; Article 12; Circumstances which exempt from
criminal liability – The following are exempt from criminal liability: 1. An
imbecile or an insane person, unless the latter has acted during a lucid interval

Laurel, J.:
On December 12, 1934, accused, Celestino Bonoan allegedly
stabbed Carlos Guison on the different parts of his body with a knife,
thereby inflicting upon him stab wounds n the liver, posterior and lateral
lumbar region, and left elbow, which caused Guison‟s death three days
afterwards. Bonoan met Carlos Guison on Avenida Rizal near a
barbershop close to Tom‟s Dixie Kitchen. Beech, who was one of the
witnesses, allegedly heard the accused say in Tagalog, “I will kill you”,
before stabbing the victim thrice on the left side. Bonoan stabbed the
latter when he refused topay the P50 debt he owed the former, and this
was evidenced by the testimony of a police officer who witnessed the
event. The accused had also been confined in the insane deparment of the
San Lasaro Hospital (suffering from dementia praecox) in 1922 and in
The defense objected to the arraignment of the said case on the
grounds that the accused was mentally deranged and at that time,
confined in the Psychopatic Hospital. Doctors of the hospital were
summoned by the court to be questioned with regard to the mental
condition of the defendant. Dr. Fernandez, one of the hospitals doctors,
appeared before the court and testified that the accused was not in a
condition to defend himself, after which, the case was suspended
indefinitely. Soon thereafter, the same doctor appeared before the court
and testified that the accuesed “had recovered from the disease.” Case
continued, accused pleaded “not guilty”
The lower court found the defendant guilty of murder and was
sentenced with life imprisonment, and to indemnify the heirs of the
deceased in the sum of P1000 and to pay the costs. Accused appealed to
this Court thenafter.

People vs Bonoan

Issue, ruling and discussion
Whether or not there is sufficient evidence to acquit the defendant on the ground
of insanity in accordance with par. 1 of article 12 of the RPC

1. Dementia precox is covered by the term insanity.
When a person is suffering from a form of psychosis, a type of
dementia praecox, homicidal attack is common because of delusions that
he is being interfered with sexually, or that his property is being taken.
During the period of excitement, such person has no control whatever of
his acts.
The unlawful act of the accused may be due to his mental disease or
a mental defect, producing an―irresistible impulse,‖ as when the accused
has been deprived or has lost the power of his will which would enable
him to prevent himself from doing the act. Here, an irresistible homicidal
impulse was considered to embrace the term ―insanity.
2. It has been proven that defendant suffered from dementia four days
before the commission of the crime, which, according to experts, is a
symptom of dementia praecox which might have revived itself even after
years of being dormant or stable In order to ascertain a person„s mental
condition at the time of the act, it is permissible to receive evidence of the
condition of his mind during a reasonable period both before and after
that time. Direct testimony is not required, nor are specific acts of
derangement essential to establish insanity as a defense. Mind can be
known only by outward acts. Thereby, we read the thoughts, the motives
and emotions of a person and come to determine whether his acts
conform to the practice of people of sound mind. To prove insanity,
therefore, circumstantial evidence, if clear and convincing, will suffice. A
person who has been adjudged inane, or has been committed to a hospital
or any asylum for the insane, is presumed to be insane.

unless the latter has acted during a lucid interval xxx Aquino. Maximino Balbas. said that Ambal suffered from a minor psycho-neurosis. She was mortally wounded. explosive or inadequate personality. SUPREME COURT REPORTS DIGEST People vs Ambal THE PEOPLE HONORATO OF THE PHILIPPINES.”) so he attacked her. motives. She asked for drinking water and medical assistance. His defense was insanity. He pleaded not guilty. Circumstances which exempt from criminal liability – The following are exempt from criminal liability: 1.: In the morning of 20 January 1977. and quarreled and bickered a lot. She told him that he was better off dead (“Mas maayo ka pang mamatay. Mambajao. thoughts. Cresogono Llacuna. The two had been married for 15 years. AMBAL. the tip of which was broken. In the Philippines. An imbecile or an insane person. He also said that Ambal was a ―passive-aggressive. the barangay captain found Felicula (Feling). because Feling had not bought medicine for Honorato. She was placed in an improvised hammock and brought to the hospital. a disturbance of the functional nervous system which is NOT INSANITY. having 7 incised wounds in different parts of her body. and he appeared to be weak.SUPREME COURT REPORTS DIGEST People vs Bonoan On insanity: the first view is that insanity as a defense in a confession and avoidance and as must be proven beyond reasonable doubt when the commissionof a crime is established. Camiguin. Mind can only be known by outward acts. The immediate provocation for the assault was a fight. The third view is that the prosecution must prove sanity beyond reasonable doubt. Feling sometimes didn„t stay in the home and spent the night in the poblacion of Mambajao. accused-appellant. the municipal health officer. conviction follows. Circumstantial evidence suffices to prove insanity. The second view is that insanity is not to be established eyond a reasonable doubt. The policeman confiscated his long bolo. Honorato admitted to killing his wife. After leaving their child to a neighbor. Article 12. and emotions of a person are read to determine whether one‟s acts conform to the practice of people of sound mind. he took a pedicab. vs. plaintiff-appellee. found him to be have suffered from―„psychosis„ due to short frustration tolerance‖ during the commission of the crime but was normal before and after the commission. Two doctors were brought to the stand: o Dr. o Dr. Then. he went to the house of the barangay captain and told the latter„s wife that he had killed Feling. His shirt was torn. Jr. They had 8 children. and was elevated to the CFI on 4 March 1977. went to the municipal hall and surrendered to a policeman. and the defense of insanity is not made out beyand a reasonable doubt. Important provision. Direct testimony is not required to establish insanity as a defense. who undertook a 2-month observation of mental cases and treated around 100 cases of mental disorders. the first view is applied. 48 and married to Honorato Ambal. and HAD NO MENTAL DISORDER. J. He was charged with parricide on 27 January 1977 in the municipal court.. who then had influenza. under some flowering plants near the couple„s house in Barrio Balbagon. he was bespattered with blood. He was normal but nervous. emotionally unstable. She died 40 minutes later. . again confessing that he killed his wife.

(Revised Administrative Code). SUPREME COURT REPORTS DIGEST People vs Ambal excused if the disease of the mind was such that he was incapable of appreciating the difference between right and wrong … not the right and wrong of particular case. he got wet while plowing.” there must be complete deprivation of intelligence in the commission of the act or that the accused acted without the lease discernment. Later. hatred. or a more or less permanently diseased or disordered condition of the mentality. But under the circumstances. “Gradually. This. functional or organic. The State should guard against sane murderers escaping punishment through a general plea of insanity. or disordered function of the sensory or of the intellective faculties. the difference … between good and evil. and that “the worst thing that can happen to a person is to have an unbearable spouse. must be deprived completely of reason or discernment and freedom of the will at the time of committing the crime.” The popular meaning of the word „crazy‟ is not synonymous with the legal terms „insane‟. Formigones) o Insane person: “one who has an unsound mind or suffers from a mental disorder. In this case. Issue. „non compos mentis‟. insanity was allowed. and that„s how he got sick. … Then the limits of the defense were expanded … The killer was . ruling and discussion Barredo. Vaquilar) Passion and motives of anger. The court presumes that a person is of sound mind unless there is positive proof stating otherwise. Mere abnormality of his mental faculties does not exclude imputability. Courts should be careful to distinguish insanity in law from passion or eccentricity. but right or wrong generally or in the abstract. should entitle him to two additional mitigating circumstances: obfuscation and illness. „unsound mind„.SUPREME COURT REPORTS DIGEST People vs Ambal Ambal said that he knew that his wife was dead because he was informed of it. or „lunatic. but only witin narrow limits. Bonoan) o Imbecile: “person marked by mental deficiency”. „idiot„. and characterized by perversion. People vs. Trial court concluded that his behavior immediately after the incident showed he wasn„t insane and that he acted like a normal human being. or by impaired or disordered volition. appellant is deserving of executive clemency. Whether or not Ambal should be exempted from criminal liability by reason of insanity Abad Santos. and that he remembered riding on a tricycle when he surrendered on the day of the killing. and so he recommends it. plus the mental disorder. this was modified in favor of the prisoner so that capacity to understand the difference between right and wrong generally would not charge with responsibility if there was no capacity to understand the difference in relation to the particular act. is not insanity either. inhibition. Trial court affirmed. Renegado) o Insanity: “a manifestation in language or conduct of disease or defect of the brain. Neither is being weak-minded.„ (US vs. J. He said that his wife was irritable and they used to quarrel a lot. the subject of the crime. mental weakness or mere depression resulting from physical ailment. (People vs. concurring: Agrees with decision based on jurisprudence. He remembered that a week before the incident. no such proof has been given. concurring: Adds the observation that Feling was a shrew. insanity wasn„t a defense. (People vs. not being in full possession of his normal mental faculties. etc. J.”She was also neglectful and even” had the gall” to tell him that he was better off dead. but that he didn„t know that he had killed his wife because at the time of the killing. es. (People vs Cruz. he didn„t know what he was doing.

He said “Mangkukulam ka. who saw SUPREME COURT REPORTS DIGEST People vs Puno this happen. is a jeepney driver. In the morning." and ENRIQUE AMURAO y PUNO. 72. Bulacan. 23. plaintiff-appellee. Barrio Tinajeros." accused-appellants. Puno introduced him to the puppy and sang an English song. He believes that there are mangkukulam. he was cuddling a puppy that he called “Diablo” and when asked to eat. he just stared at Teotimo. Regalado. Puno„s father surrendered him to the police. ISABELO PUNO y GUEVARRA. Calumpit. Araceli Maravilla from the Psychiatry Section of Dr.traumatic hemorrhage. At about 2pm of 8 Sept 1970. vs. alias "Beloy. [Schizophrenics] may retain some residual symptoms impairing their judgment but not necessarily their discernment of right from wrong of the offense committed. o Dr. He found her body. Reynaldo Robles of National Mental Hospital: symptoms were “not socially incapacitating” and that he could adjust to the environment. Puno then went upstairs and got the cord of the religious habit of his mother. abuse of superiority and disregard of sex. Lina went to the police anyway and told Corporal Daniel B. If he were truly insane at the time. He wouldn„t have reached third year HS if he were. then asked for another rope when Zenaida told him not to use it. Puno knew what he was doing and that he had psychosis. The … amnesia of several isolated accounts … do not fit the active pattern of a schizophrenic process. he was awakened by the sound of people in the flood. (It was flooded there then. He was brought to National Mental Hospital in Mandaluyong on 10 Sept 1970. While lying down. testified that on the night before the murder. mambabarang and mabubuyog and that one harmed by a mambabarang might have a headache or aswelling nose and ears and can be cured only by an herbolaryo. and Ernesto thought they were his fellow cursillistas. Later. Cruz what happened. who is a widow. he said that a bumblebee was coming towards him and he warded it off with his hands. He was charged with murder in the municipal court and was indicted in the Circuit Criminal Court at Pasig on 21 Oct 1970. Rizal. he would„ve killed the two witnesses as well. his wife. mambabarang. didn„t eat but fed the puppy instead. Puno tied their dog to a tree and repeatedly boxed it.and his look was baleful and menacing. he started singing again. given that he had been suffering chronic schizoprenia before the crime was committed . Autopsy showed that Aling Kikay had lacerated wounds on her right eyebrow and contusions on the head caused by a hard instrument. mayroon kang bubuyog” then slapped her and struck her several times on the head with a hammer until she was dead. 27. who all testified that Puno acted with discernment: o Dr. Zenaida Gabriel. Puno testified that he didn„t remember killing Aling Kikay. while he was feeding pigs. J.” Trial Court said he knew what he was doing at the time and that he would be punished for it. Malabon. he entered a bedroom in the house of Francisca Col (Aling Kikay). his eyes were red. Issue. Vicente: not suffering from any delusion and was not mentally deficient. According to them. 28. o The report of the three doctors submitted on 14 Dec 1970 said that he is “presently free from any social incapacitating psychotic symptoms. his eyes were reddish and that hecomplained of a headache. The following day. Court cited as aggravating circumstances evident premeditation. Puno was convicted of murder and sentenced him to death. He then went to his parents„ house in Barrio Tugatong. Jose R. Reyes Memorial Hospital: Puno was an outpatient who could very well live with society although he was afflicted with ”schizophrenic reaction”. tookthe statements of the witnesses down at the police station. He threatened the two and told them not to go to the police. then made a moaning sound until he fell asleep.also said that his eyes were bloodshot and he had a ferocious expression about him.: Ernesto Puno. There were two witnesses: Hilaria de la Cruz. but Zenaida didn„t see any bee.SUPREME COURT REPORTS DIGEST People vs Puno PEOPLE OF THE PHILIPPINES. It is also necessary to kill the mangkukulam and mambabarang. ruling and discussion Whether or not Puno was insane at the time of the commission. then to his second cousin„s (Teotino Puno„s) house in Barrio San Jose. According to Teotimo. o Dr. The house is in Little Baguio. Aling Kikay was in bed. and Lina Pajes. records don„t show how he got there). Agrees with Maravilla. Defense brought 3 psychiatrists. and refused to change his clothes (which were wet because of the flood). Aida Gabriel. COD: intracranial. alias "Enry. when Puno came to his house on 8 Sept. 30. he tried on Teotimo„s father„s clothes and when told that Teo„s father had been dead for a couple of years. which was why he threatened the witnesses.

Based on the reports of their staff. It was also barely a month and 15 days since his last attack. Paras. she heard people saying that a stabbing occurred. After which he departed from the office with blood stained clothes. during and after the commission of the alleged crime and classified his insanity as an organic mental disorder secondary to cerebro-vascular accident or stroke. I have cancer of the heart. the accused went to Mrs. ang nasabi na lang ni Aling Kikay ay “Diyos ko.” That same day. But Dr. so the interval was not sufficient time for his full recovery.” His records never showed that he was cured. The autopsy report revealed that the victim sustained 14 wounds. carrying a bloodied bladed weapon. ROSALINO DUNGO. The accused. must be characterized by “total deprivation of freedom of the will. Ambal)” Puno was not legally insane when he killed Aling Kikay. If I don't kill the deceased in a number of days. vs. 1987. He killed the “mangkukulam” as personified by the victim. penalty should only be in medium terms.” SUPREME COURT REPORTS DIGEST People vs Dungo PEOPLE OF THE PHILIPPINES. Santiago and Dr. J. he went back to the store. His condition may simply be “in remission” which term means “social recovery. to which Rosalino answered.”) There wasn„t any premeditation proven. as per order of the trial court dated Aug. She asked her husband why he did the act.Insanity. On her way home. but with minor symptoms and signs…” What happened was a relapse. Vicente. Articles cited by Makasiar shows that „social recovery‟ is not the same as being „cured‟: “By this it is meant that the patient is able to return to his previous social environment and to previous or equivalent occupation. 5 of which were fatal. Mere abnormality of the mental faculties will not exclude imputability. But when Andrea followed him to the store. the accused Rosalino Dungo inquired from him why his wife was requiring so many documents from him. Apalit. She saw her husband in her parentsin-law's house with people milling around. Sigua several times. Thereafter. Sigua's office at the Department of Agrarian Reform. maltreating their children when he was not used to it before. and he was not completely deprived of reason and freedom of will. nor disregard of sex. plaintiff-appellee. Dr. Worried. he was no longer there. the accused drew a knife from the envelope he was carrying and stabbed Mrs. Balatbat who treated the accused for ailments secondary to stroke. Death Penalty set aside to Reclusion Perpetua. I would die. so he killed her in self-defense. Makasiar. his power of control over his will to commit a crime is affected in such a way that “one who has the impulse to kill will kill‖ when he is affected by such an ailment. 1987 between 2:00 and 3:00pm. tried to show that he was insane at the time of the commission of the offense: appears to be in deep thought always. “The victim was a mere consequence of his mental delusion. accused-appellant. J. only that he was “improving” and “treatment not completed. After a brief talk. as shown by the facts and findings of the psychiatrists. in defense of himself. testified that sometime in February 1987.SUPREME COURT REPORTS DIGEST People vs Puno No. Rodolfo explained to him the procedure at the DAR. Echavez of the National Center for Mental Health testified that the accused was confined in the mental hospital. therefore. husband of the deceased. The said ailment is characterized by inability to distinguish between fantasy and reality and often accompanied by hallucinations and delusions. Vicente also said that he could„ve been suffering from an onset of the schizo reaction at the time. (People vs. There were also times that her husband would inform her that his feet and head were on fire when in truth they were not. 17. they concluded that Rosalino was psychotic or insane long before. Rodolfo Sigua. Murder is correct because there was abuse of superiority (as in. He was convinced that a mangkukulam was inflicting harm on him. she looked for him. idn't bother to buy medicine as the pain went away immediately. “For chronic schizophrenia. he did not kill Aling Kikay herself. "That's the only cure for my ailment. Lim who testified that the accused suffered dorm occlusive . and Dr. the accused went to Manila. dissenting: Appellant had been ailing with a psychotic disorder medically known as chronic schizophrenia even before he committed the crime. the patient does not recover fully in two months„ time. to be pleaded.” According to Dr. On March 16. Pampanga.

indicate that he was conscious and knew the consequences of his acts in stabbing the victim. Appellant caught up with Jerry and stabbed him on the left portion of his back. Cebu to deliver benignit to his aunt Bebing Dequiado. This also established that the accused has lucid intervals. Amanda Ceniza to Bgy. Appellant struck at Danilo who got hit on the bridge of his nose. accused-appellant. which is manifested in language or conduct. Antonio Yapha who said that the testimony of the appellant that he was shot by Danilo is improbable as a gunshot would not have caused a prolapse (intestine slipping out of the usual place).” and immediately hacked Danilo . Sigua. Pinamungajan. ruling. and discussion . In addition. it states that insanity is evinced by a deranged and perverted condition of the mental faculties. However. there's no definite test or criterion for insanity. Tutay. From this. Dr. o Jerry Tejamo was with Julius. He informed Ancieta Tejamo. Evidence of insanity must refer to the mental condition at the very time of doing the act. They passed by the house of the accused who greeted them. concluded that Rosalino was somehow rehabilitated after a series of medical treatment in their clinic. J. An insane person has no full and clear understanding of the nature and consequence of his act. the accused unsheathed a long bolo and ran after the two. In essence. SUPREME COURT REPORTS DIGEST People vs Yam-id PEOPLE OF THE PHILIPPINES. “Good Evening” and after the greeting. After Danilo asked the appellant where his son was. Ancieta and Danilo ran to the site of the incident but before reaching the place they were met by the appellant. it is necessary that there be a complete deprivation of intelligence in committing the act. that he acts without the least discernment and that there be complete absence or deprivation of the freedom of the will. who thereafter told Danilo. Sigua. The defense of insanity is anchored on the testimony of Dr. Issue. the definition of insanity under Sec 1039* of the Revised Administrative Code can be applied. The appellant denied killing Jerry during the trial and pleaded selfdefense for his assault at Danilo . At the automatic review at the Supreme Court. Danilo Tejamo. For insanity to relieve the person of criminal liability. the accused was able to Mrs. ERLINDO YAM-ID alias ELY. (This was taken from the trial court's decision). wife of Danilo. plaintiff-appellee. The fact that the accused was carrying an envelope where he hid the fatal weapon. But in the case at hand. Danilo was able to dodge the attack but he fell to the ground. Under Philippine jurisdiction. “I will kill all of you. Julius Cantutay was sent by his grandmother. 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. and discussion Whether or not the accused was insane during the commission of the crime No. As Jerry fell to ground. the appellant admitted to killing Jerry and pleaded insanity as his defense which contends that he has schizophrenia. then held him by the hair and hacked him on the nape. it can be inferred that the accused was aware of his acts. Issue. This statement makes it highly doubtful that the accused was insane when he committed the act. Appellant then ran towards his house and threw the bolo to the ground. Julius ran towards the house of Jerry to the latter„s father. they claimed that the appellant„s gruesome action of sucking Jerry„s blood after he killed him is further proof of insanity Judgment: questioned decision AFFIRMED. ruling. It is not usual for an insane person to confront a specified person who may have wronged him. that he ran away from the scene of the incident after he stabbed the victim several times. Danilo regained consciousness and sought treatment. However. Melo. Julius pushed Jerry and told him to run but Jerry was eventually overtaken by Julius. Danilo tried to stand by appellant hacked him again and hit him in the head o The tip of the bolo hit appellant„s stomach when he held Danilo by the collar to finish him off. appellant answered. The vagaries of the mind can only be known by outward acts. vs. the appellant further stabbed him on the right side of his back then the appellant knelt over the prostrate body of Jerry and sucked the blood from his neck. Moreover.SUPREME COURT REPORTS DIGEST People vs Dunga Lim who testified that the accused suffered dorm occlusive disease. 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. that he fled to Manila to evade arrest.

and discussion . she announced that Ramy was stabbed. On January 6. Randy tried to force his way in front of the opening and as a consequence. Insanity must be proven beyond reasonable doubt to be existing before or at the very moment the crime was committed. and relied on the expert assessment of his witness. Without saying a word and without warning. Dr. The accused came over and sat on the other end of the bench. he bumped on Ramy.SUPREME COURT REPORTS DIGEST People vs Dunga SUPREME COURT REPORTS DIGEST People vs Belonio Whether or not the appellant can use the defense of insanity in killing of Jerry Tejamo PEOPLE OF THE PHILIPPINES. ruling. Then the accused asked Ramy for the latter„s cigarette lighter and conversed with him. she heard another thudding sound of a stabbing blow. Jennifer stood up and ran towards her house shouting for help. the late Ramy Tamayo. Per Curiam: RTC found Randy Belonio y Landas guilty of the murder of Ramy Tamayo and sentenced him to death. Ramy was hit on the right chest. Randy Belonio raised the defense of insanity. Antonio Gauzon. vs. Also. appellant. Her first cousin. When Jennifer entered her house.” RTC found appellant guilty of Murder and that he had full control of his mental faculties.M. Issue. saw him and noticed that he was wearing long sleeves. The store was furnished with a small opening for the store-keeper to attend to the customers and Ramy was occupying that space in front of the opening to pay when the accused Randy Belonio arrived. There at the gate of the fence of her house. by whoever invokes it as a defense o Defense failed to discharge its burden of proving that accusedappellant was insane at the time of the commission of the crime. appellee. who was facing the direction of the approaching accused. Chronic Undifferentiated and probably triggered by (s)ubstance abuse of Shabu and Marijuana. 2000. Jennifer saw that Randy gave Ramy a long and hard look. Jennifer. Jennifer invited Ramy to talk outside of their house. No. RANDY BELONIO y LANDAS. Jennifer and Ramy sat and talked on the bench. Ramy Tamayo could not see the accused as he was facing sideways to Jennifer. Ramy decided to buy cigarettes from a store only a few meters away. an exempting circumstance. the accused delivered a stabbing blow with a dagger which was concealed in his hand. The accused ran away towards the back of the barangay hall but was later arrested from one (1) of the houses near the barangay hall where he took refuge. No medical certificate was presented to substantiate the claim of insanity and no expert testimony was proffered to support the allegation. The accused left but after a few minutes he returned. Jennifer Carampatana„s grandmother was buried and there was a wake in their house in the evening. Before they could sit on a nearby bench. arrived in their house with his wife around 10:00 P. no evidence was presented that the accused was insane at the time of the commission of the crime and the fact that the defense of insanity was not even raised during the trial of the case gives the impression that is but an afterthought. who certified thus: “This is an individual who is suffering from (Schizophrenia).

defendant-appellant. at best. Important provision. he met his wife who seemed to say to him that she was wounded. Whoever invokes insanity as a defense has the burden of proving its existence. In the case at bar. he left and came back armed with a dagger with which he stabbed Tamayo. In the eyes of the law. he armed himself with a bolo and left the room. a fiesta was being celebrated in the said barrio and guests were entertained in the house. died five days later as a result of the wound. That's why he got up and it seemed to him that his enemies were inviting him to come down. However. The apparent lack of . An imbecile or an insane person. sat near the latter. the evidence of insanity after the fact of commission of the offense may be accorded weight only if there is also proof of alleged abnormal behavior immediately before or simultaneous to the commission of the crime. therefore. When he was about to go down. The only other evidence of insanity that appellant pointed to is the medical certificate prepared by Dr. He also attacked Fred and Luis and tried to attack his father. he fancied seeing his wife really wounded and in desperation wounded himself. 2000 (around nine months after the stabbing incident) the latter was suffering from schizophrenia. At the door. plaintiff-appellee. left the room bolo in hand and. weren„t voluntary in the sense of entailing criminal liability. had a severe stomachache that's why he went to bed in the early afternoon. As his enemies seemed to multiply around him. The trial court found Potenciano guilty of parricide and was sentenced to reclusion perpetua.vs. The evidence adduced by the defense is sorely insufficient to establish his claim that he was insane at the time he killed Tamayo. Immediately thereafter. the defendant had a quarrel over a glass of "tuba" with Collantes and Abadilla. he dreamed that Collantes was trying to stab him with a bolo while Abadila held his feet. upon meeting his wife who tried to stop him. 1932. who invited him to come down and fight. Afterwards. who was 7 months pregnant at that time. a circuitous argument. the doctor pointed to the fact that he has already killed three (3) persons. and was capable of distinguishing right from wrong. Dr. he escaped and went into hiding. No. he would not have attempted to escape and go into hiding. lighted his cigarette and conversed with him. Antonio Gauzon stating that Belonio was suffering from schizophrenia. after giving the victim a hard and resentful look. insanity exists when there is a complete deprivation of intelligence in committing the act. he was stopped by his wife and his mother. Ormoc. and discussion Whether or not defendant acted while in a dream Yes. On January 16. The story narrated by the doctor was a mere life and family history of Belonio. the veracity of these findings is belied by the fact that the accused did not raise this defense during his prosecutions for the other killings. The defendant stated that when he fell asleep. It appears from the evidence that the day before the commission of the crime. Potenciano went to sleep and while sleeping. it was noted that the defendant was sad and weak. he attacked everybody that came his way. if it can be shown that the offender was not completely deprived of freedom and intelligence.J. C. To demonstrate that he had been suffering from this condition. he wounded himself. On the day of the commission of the crime. Article 12. Early that afternoon. Dr.SUPREME COURT REPORTS DIGEST People vs Belonio SUPREME COURT REPORTS DIGEST People vs Taneo Whether or not appellant‟s defense of insanity as an exempting circumstance is tenable THE PEOPLE OF THE PHILIPPINE ISLANDS. such conclusion is non sequitur and. Issue. Further. The defendant acted while in a dream & his acts. These acts tend to establish that Belonio was well aware of what he had just committed. POTENCIANO TANEO. Belonio. among them were Fred Tanner and Luis Malinao. wounded her in the abdomen. There was no showing that he was actually suffering from schizophrenia during his juvenile years. unless the latter has acted during a lucid interval xxx Avanceña. after which. including the present incident. he suddenly got up. Guazon„s report was silent as regards the incidents occurring prior to or during the circumstance for which Belonio stands trial. Then. Gauzon testified that based on his interview with Belonio on October 25. No other circumstances evincing its existence were presented during trial. Circumstances which exempt from criminal liability – The following are exempt from criminal liability: 1. Otherwise. However. ruling.: Potenciano Taneo and his wife lived in his parent's house in Dolores. Potenciano's wife. Proof of the existence of some abnormality of the mental faculties will not exclude imputability. the defense utterly failed to discharge its burden of proving that appellant was insane.

but also motives for not committing the acts. he got his cousin's (Romualdo Cocal) knife. Juan Ragojos and Epifanio Rarang were playing volleyball in the yard of their school in Sual. When such minor is adjudged to be criminally irresponsible. shall commit him to the care and custody of his family who shall be carged with his surveillance and education. who was hit in the stomach. After doing this. Important provision. otherwise. defendant-appellant.: Between 1-2 pm of Nov. stated that considering the circumstances of the case. Although an extreme moral perversion may lead a man to commit a crime without a real motive but just for the sake of committing it. the accused. 3. The wife's wound may have been inflicted accidentally. and was an officer in the CAT program). Circumstances which exempt from criminal liability – The following are exempt from criminal liability: xxx 2. in conformity with the provisions of this and the preceding paragraph. 1938. slapped Doquena on the nape. but that simply they are not known to us. plaintiff-appellee. J. the court. Diaz. A person under 9 years of age. the appeal by the accused. under the influence of a hallucination and not in his right mind.VALENTIN DOQUEÑA. but that he was defending himself from his enemies.. and punched him in the face. . and thus convicted him of the crime of homicide. the following must be taken into consideration: a) The facts and circumstances which gave rise to the act committed. 19. and threw it a Ragojos. in which case. therefore his defense that he was a minor was untenable (given that the Doquena was a 7th grade pupil. an expert witness in the case. and confronted Ragojos. intercepted the ball. finding none. vs. Doquena looked for something to throw at Ragojos. Ragojos went back to Rarang to resume playing volleyball. Ragojo's denied Doquena's request for a fight and resumed playing. the accused acted with discernment and was conscious of the nature and consequences of his acts. Dr. The defendant did not dream that he was assaulting his wife.SUPREME COURT REPORTS DIGEST People vs Taneo motive for committing a criminal act does not necessarily mean that there are none. Doquena stabbed the unaware Ragojos in the chest. the defendant acted while in a dream. Insulted. he shall be committed to the care of some institution or person mentioned in Article 80. the court found not only lack of motives for the defendant to voluntarily commit the acts complained of (read: he loved his wife dearly. The court ordered him to be sent to the Training School for Boys until he reaches the age of majority. b) The state of mind at the time the crime was committed c) The time he had at his disposal d) The degree of reasoning of the minor. Article 12. he tried to attack his father in whose house the lived and the guests whom he invited). and upon catching him. Thus. stating that to determine whether or not there was discernment on the part of the minor. such minor shall be proceeded against in accordance with the provisions of Article 80 of this Code. Pangasinan. Serafica. Miffed. It was also ordered that he be confined in the government insane asylum and will not be released until the director thereof finds that his liberty would no longer constitute a menace SUPREME COURT REPORTS DIGEST People vs Doquena THE PEOPLE OF THE PHILIPPINES. The court held that in committing the act. Judgment: defendant not criminally liable for the offense. Ragojos chased Doquena. In the case at hand. A person over nine years of age and under fifteen. Valentin Doquena. one of the brightest in his class. unless he has acted with discernment. thereby killing the latter.

because Omamdam had passed behind him. If. Bindoy did not try to wound Pacas. vs. Bindoy appealed. No evidence that Bindoy was aware of Omamdam's presence. or at least for lack of intention. The testimony of this witness was not contradicted by any rebuttal evidence adduced by the fiscal. On the contrary. 1930.SUPREME COURT REPORTS DIGEST People vs Doquena Issue. 8 of the Revised Penal Code. who was then behind Bindoy. Bindoy succeeded in disengaging himself from Pacas. No evidence that there was disagreement or ill feelings between Bindoy & Omamdam. although the wrongful act done is different from that which he intended. ruling. the very appearance. while performing a lawful act with due care.: On May 6.. This is not the case here. wrenching the bolo from the latter's hand. who was therefore hit in the chest. The disturbance attracted the attention of Emigdio Omamdam. not only before and during the commission of the act. which Pacas was trying to wrench away from him. Accused mistakes the discernment for premeditation. since whoever willfully commits a felony or a misdemeanor incurs criminal liability. doing so. the very comportment and behavior of said minor. and discussion Whether or not the crime can be mitigated on the ground of accident Yes Decision is reversed. the former had pulled so violently that it flew towards Omamdam. His conduct was perfectly lawful Important provision. Whether or not the accused had discernment Yes. without Bindoy's seeing him. He was only trying to defend his possession of the bolo. is his MENTAL CAPACITY to understand the difference between right and wrong. and discussion SUPREME COURT REPORTS DIGEST People vs Bindoy THE PEOPLE OF THE PHILIPPINE ISLANDS. & were on good terms with each other. he would be liable for his act. and instead of. In the course of the struggle. had wounded Omamdam. Any person who. DONATO BINDOY. and such capacity may be known and should be determined by taking into consideration all the facts and circumstances afforded by the records in each case. She refused and Bindoy threatened to injure her if she did not accept. The trial court held that Bindoy was guilty of the crime of homicide. J. but also after and even during the trial. The witness for the defense corroborates the defendant to the effect that Pacas and Bindoy were actually struggling for the possession of the bolo. However. causes an injury by mere accident without fault or intention of causing it. Pacas stepped in to defend his wife and attempted to take away from Bindoy the bolo he carried. and that when the latter let go. the DISCERNMENT that constitutes an exception to the exemption from criminal liability of a minor under 15 years but over nine. Faustino Pacas' wife. ruling. . the defendant had attempted to wound his opponent. There is no evidence to show that Bindoy deliberately and intentionally killed Omamdam. No. alleging that the death of Omamdam was caused accidentally and without malicious intent. in the struggle. Issue. Article 12. as a mitigating circumstance. they were nephew & uncle. xxx Villamor. plaintiff-appellee. the very attitude. Donato Bindoy offered some tuba to Tibay. Bindoy is acquitted according to Article 8. defendant-appellant. Circumstances which exempt from criminal liability – The following are exempt from criminal liability: xxx 4. The accused acted with discernment. No evidence that Omamdam took part in the fight between Bindoy and Pacas. with such violence that the point of the bolo reached Omamdam's chest. who commits an act prohibited by law.

His conduct was perfectly lawful Code of Criminal Procedure: A defendant in a criminal action shall be presumed to be innocent until the contrary is proved. which Pacas was trying to wrench away from him. but simultaneously. the latter's Mother & Uncle. which they did by putting it amidst the tall cogon grass. The accused went into the forest upon the recommendation of the deceased to continue his search for the elusive wild chickens. accessories. the accused denied all knowledge of the crime. CECILIO TAÑEDO. Cecilio Tanedo. Feliciano Sanchez.: On January 26. Article 1 of the Penal Code: Crimes or misdemeanors are voluntary acts and omissions punished by law… b. Accused was sentenced to 14 yrs. Article 8: He who while performing a legal act with due care. Also. ruling. Prior to the trial. causes some injury by mere accident without liability or intention of causing it. to help him hide the body. Tanedo shot one. and discussion Whether or not accused is guilty No. Tanedo ran back to his workers and asked one. Article 12. After seeing that Sanchez was wounded. Only 1 shot was heard that morning & a chicken was killed by a gunshot wound.. Chicken feathers were found at the scene of the crime. The accused appealed. Any person who. vs. according to: a. Circumstances which exempt from criminal liability – The following are exempt from criminal liability: xxx 4. since whoever willfully commits a felony or a misdemeanor incurs criminal liability.SUPREME COURT REPORTS DIGEST People vs Bindoy doing so. causes an injury by mere accident without fault or intention of causing it. meeting the victim. Upon reaching the dam. there having only one shot fired. There was no enmity between the accused and the deceased. he heard a human cry out in pain. The lower court found the accused guilty of homicide. having invited the deceased into the forest & intentionally shooting him in the chest. Section 57 of . Upon seeing one. C. the accused went on his way to hunt for wild chickens. and in case of a reasonable doubt that his guilt is satisfactorily shown he shall be entitled to an acquittal. This is not the case here. Bindoy did not try to wound Pacas. but later confessed during the trial. plaintiff-appellee. defendant-appellant. 8 mos & 1 day of reclusion temporal. SUPREME COURT REPORTS DIGEST US vs Tanedo THE UNITED STATES. Bernardino Tagampa. although the wrongful act done is different from that which he intended. a landowner. indemnifications & costs. Issue. while performing a lawful act with due care. & later burying in an old well. Important provision. carrying with him his shotgun & a few shells. J. he would be liable for his act. 1909. He was only trying to defend his possession of the bolo. went with some workers to work on the dam on his land. The idea that Tanedo intended to kill Sanchez is negated by the fact that the chicken and the man were shot at the same time. xxx Moreland. had wounded Omamdam.

nor is there evidence that the accused intended to kill the deceased. and discharged from custody. because there is a denial of intentional killing. and in case of a reasonable doubt that his guilt is satisfactorily shown he shall be entitled to an acquittal. and the burden is upon the state to show that it was intentional. The court quoted State vs. both that for the state and the prisoner. and if. In this case there is no evidence of negligence on the part of the accused. The only thing suspicious is his denial of the act and his concealment of the body. the jury should acquit. the accused is not required to prove such a defense by a preponderance of the evidence. Legg: "Where accidental killing is relied upon as a defense. nor is it disputed that the accused was engaged in a legal act. from a consideration of all the evidence. there is a reasonable doubt as to whether or not the killing was accidental or intentional. . Decision: Judgment of Conviction is reversed." Court held that the evidence was insufficient to support the judgment of conviction. the accused acquitted.SUPREME COURT REPORTS DIGEST US vs Tanedo Code of Criminal Procedure: A defendant in a criminal action shall be presumed to be innocent until the contrary is proved.