The People of the Island of the Philippines VS.

PotencianoTaneo
G.R. No. L-37673 March 31, 1933

Nature of Actions
: An appeal from the judgment of Regional Trial Court, Branch 5 of Cebu City.

Facts: Potenciano Taneo lives in the house of his wife’s parents in a barrio of Ormoc, Leyte. On
January16, 1932, a fiesta was being celebrated in the said barrio and visitors were entertained in the
house. Among them were Fred Tanner and Luis Malinao. Earlier in the afternoon he fell ill and
slept early. While dreaming, he stood up with a bolo on his hand, and upon meeting his seven-
month-pregnant wife who tried to stop him, he wounded her which caused her death 5 days later
because of the inflicted wound. He also wounded his visitors, Tanner and Malinao, even his wife’s
father, and lastly, himself.
The trial court found Potenciano guilty of parricide and was sentenced to reclusion perpetua.
It appears from the evidence that the day before the incident, Potenciano had a quarrel over a
glass of “tuba” with Enrique Collantes and Valentin Abedilla, who invited him to come down to fight, and when he was
about to go down, he was stopped by his wife and his mother. And on the day of the incident, it was
noted that he was sad and weak, and had a severe stomach ache which was the reason why he
slept early. It was then when he fell asleep, Potenciano states that he dreamt that Collantes was
stabbing him with a bolo and Abedilla was holding his feet, by reason of which he got up and
defended himself by getting the bolo and leaving the room. The evidence also shows that
Potenciano not only did not have any trouble with his wife, but that he loved her dearly. Neither did
he have any dispute with Tanner and Malinao or have any motive for assaulting them.

Issue: Is Potenciano Taneo criminally liable of the felony he committed?

Ruling: In view of all these considerations, and reserving the judgment appealed from, the court
finds that the defendant is not criminally liable for the offense with which he is charged, and it is
ordered that he be confined in the Government Insane Asylum, whence he shall not be released
until the director thereof finds that his liberty would no longer constitute a menace, with costs
de oficio. So ordered.

Ratio Decidendi: The defendant acted in a dream which shows his lack of intent and motive, and
his actions are not voluntary, therefore his acts do not constitute a criminal liability and must not be
given such penalty and punishment. Dr. Serafica, an expert witness of the case, stated that the
defendant acted while in a dream, under the influence of a hallucination and not in his right mind.
Although there was a lack of motive and intent, it does not necessarily mean that he is not criminally
liable, but that they are not known to us. In this case, the court found that there was insufficient
evidence of intent to do such crime (Potenciano not only did not have any trouble with his wife, but
that he loved her dearly) but also motives to do the act voluntarily. Hence, it is justifiable that the
judgment he appealed from should be reversed, and that it is also justifiable that he be detained in
the Gov’t Insane Asylum, until he is well enough to be released
 People v. Bonoan, L-45130, 17 February 1937

Facts:
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 imprisonment.

The defense now appeals, claiming the lower court made errors in finding Bonoan suffered dementia
only occasionally and intermittently, did not show any kind of abnormality, that the defense did not
establish the defendant’s insanity and finding accused guilty.

Issue:
W/N the lower court erred in finding the accused guilty

Held:

Yes. The Court finds the accused demented at the time he perpetrated the crime, which
consequently exempts him from criminal liability, and orders for his confinement in San Lazaro
Hospital or other hospital for the insane. This ruling was based on the following evidence:
1. 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
2. Persons with dementia praecox are disqualified from legal responsibility because they have no
control of their acts; dementia praecox symptoms similar to manic depression psychosis
3. Accused had an insomnia attack, a symptom leading to dementia praecox, four days prior to act
according to Dr. Francisco
4. Accused was sent the Psychopatic hospital on the same day of crime and arrest, indicating the
police’s doubt of his mental normalcy
5. Defendant suffered from manic depressive psychosis according to Dr. Joson

Dissenting (Justices Imperial, Diaz and Concepcion):

1. The dissenting opinions pose that the accused committed the crime when he was sane, or at least,
during a lucid interval.
2. The legal presumption is always in favor of sanity; no positive evidence of accused mental state was
established
3. Based on expert testimonies, accused was cured of dementia praecox and later manic depressive
psychosis
4. Based on observance of arresting officer Damaso Arnoco, corrobating statement of Benjamin Cruz,
and other witnesses, accused appear sane at the time immediately after commission
5. There is a motive of aggression on part of accused is real and positive fact: deceased’s failure to pay
borrowed money
PEOPLE v. DUNGO [199 SCRA 860 (1991)]

G.R. No. 89420. July 31, 1991.*

Nature: Automatic review of the decision of the RTC of Pampanga convicting the accused of murder.

Facts: On March 16, 1987 between 2:00 and 3:00pm, the accused went to Mrs. Sigua's office at the
Department of Agrarian Reform, Apalit, Pampanga. After a brief talk, the accused drew a knife from
the envelope he was carrying and stabbed Mrs. Sigua several times. After which he departed from the
office with blood stained clothes, carrying a bloodied bladed weapon. The autopsy report revealed that
the victim sustained 14 wounds, 5 of which were fatal.

Rodolfo Sigua, husband of the deceased, testified that sometime in February 1987, the accused
Rosalino Dungo inquired from him why his wife was requiring so many documents from him. Rodolfo
explained to him the procedure at the DAR.

The accused, in defense of himself, tried to show that he was insane at the time of the commission of
the offense:

 Two weeks prior to March 16, 1987, Rosalino's wife noticed that he appears to be in deep thought
always, maltreating their children when he was not used to it before. There were also times that
her husband would inform her that his feet and head were on fire when in truth they were not.
 On that fateful day, Rosalino complained of stomachache but they didn't bother to buy medicine as
the pain went away immediately. Thereafter, he went back to the store. But when Andrea followed
him to the store, he was no longer there. Worried, she looked for him. On her way home, she heard
people saying that a stabbing occurred. She saw her husband in her parents-in-law's house with
people milling around. She asked her husband why he did the act, to which Rosalino answered,
"That's the only cure for my ailment. I have cancer of the heart. If I don't kill the deceased in a
number of days, I would die.” That same day, the accused went to Manila.

Dr. Santiago and Dr. Echavez of the National Center for Mental Health testified that the accused was
confined in the mental hospital, as per order of the trial court dated Aug. 17, 1987. Based on the
reports of their staff, they concluded that Rosalino was psychotic or insane long before, 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. But Dr. Balatbat who treated the accused for
ailments secondary to stroke, and Dr. Lim who testified that the accused suffered dorm occlusive
disease, concluded that Rosalino was somehow rehabilitated after a series of medical treatment in
their clinic.

Issue: WON the accused was insane during the commission of the crime charged.
Held: No. For insanity to relieve the person of criminal liability, it is necessary that there be a complete
deprivation of intelligence in committing the act, that he acts w/o the least discernment and that there
be complete absence or deprivation of the freedom of the will.

Under Philippine jurisdiction, there's no definite test or criterion for insanity. However, the definition of
insanity under Sec 1039* of the Revised Administrative Code can be applied. In essence, it states that
insanity is evinced by a deranged and perverted condition of the mental faculties, which is manifested
in language or conduct. An insane person has no full and clear understanding of the nature and
consequence of his act.

Evidence of insanity must refer to the mental condition at the very time of doing the act. However, 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. The vagaries of the mind can only be known by outward acts.

It is not usual for an insane person to confront a specified person who may have wronged him. But in
the case at hand, the accused was able to Mrs. Sigua. From this, it can be inferred that the accused
was aware of his acts. This also established that the accused has lucid intervals.

Moreover, Dr. 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. This statement makes it highly doubtful that the accused was insane when he committed
the act.

The fact that the accused was carrying an envelope where he hid the fatal weapon, that he ran away
from the scene of the incident after he stabbed the victim several times, that he fled to Manila to evade
arrest, indicate that he was conscious and knew the consequences of his acts in stabbing the victim.
(This was taken from the TC's decision).

Judgment: questioned decision AFFIRMED.

PEOPLE vs. RAFANAN G.R. No. L-54135 November 21, 1991

What are the tests to determine insanity? What was previous name of schizophrenia?
FACTS: The 14 year old victim was hired by the mother of the appellant as a househelper. One
evening, she was forced by the appellant to have sexual intercourse using a bolo on her neck as a
threat if she does not cooperate. After the abuse, he also threatened to kill her if she reports what
happened to anyone. After a few days, the victim finally told her mother about what happened
leading to the arrest and conviction of the appellant of the crime of rape.
The commission of the crime was not seriously disputed by appellant. But the principal submission
of appellant was that he was suffering from a metal aberration characterized as schizophrenia when
he inflicted his violent intentions upon the victim. The trial court suspended the trial and ordered that
the appellant be confined at the National Mental Hospital in Mandaluyong for observation and
treatment. In the meantime, the case was archived. Appellant was admitted into the hospital on 29
December 1976 and stayed there until 26 June 1978. The appellant was diagnosed to be indeed
suffering from schizophrenia by his attending physicians but was deemed fit to stand trial upon
almost 1 ½ years of treatment.
ISSUE: Whether or not the appellant should be exempted from liability for the crime on the grounds
of insanity
RULING: The court rejected the insanity defense of appellant and affirmed the lower court’s decision
convicting the appellant of the crime of rape.
For the defense of insanity to be sustained it is critical that there is complete loss of intelligence at
the time of the commission of the crime. The fact that appellant threatened the victim with death
should she reveal she had been sexually assaulted by him, indicates, to the mind of the Court, that
the apellant was aware of the reprehensible moral quality of his assault.
The law presumes every man to be sane. A person accused of a crime has the burden of proving his
affirmative allegation of insanity. In this case the appellant failed to present clear and convincing
evidence regarding his state of mind immediately before and during the sexual assault on the victim.
Schizophrenia formerly called dementia praecox, is a chronic mental disorder characterized by
inability to distinguish between fantasy and reality, and often accompanied by hallucinations and
delusions
In People vs. Formigones, the Court elaborated on the required standards of legal insanity and
established two distinguishable tests
(a) THE TEST OF COGNITION — "complete deprivation of intelligence in committing the [criminal]
act,"
(b) THE TEST OF VOLITION — "or that there be a total deprivation freedom of the will."
But our caselaw shows common reliance on the test of cognition, rather than on a test relating to
"freedom of the will;" examination of our caselaw has failed to turn up any case where this Court has
exempted an accused on the sole ground that he was totally deprived of "freedom of the will," i.e.,
without an accompanying "complete deprivation of intelligence." In any case, where the accused
failed to show complete impairment or loss of intelligence, the Court has recognized at most a
mitigating, not an exempting, circumstance in accord with Article 13(9) of the Revised Penal Code:
"Such illness of the offender as would diminish the exercise of the will-power of the offender without
however depriving him of the consciousness of his acts."
 People vs. Madarang
G.R. No. 132319. May 12, 2000
Ponente: Puno, J.
Topic: Insanity/Imbecility: Basis of Exception

FACTS:
Fernando Madarang was charged with parricide for killing his wife Lillia Madarang. He
refused to enter a plea during arraignment, and so was entered as “not guilty” in accordance to the
rules of court. Counsel for the accused manifested that his client had been observed exhibiting
abnormal behavior. Court decided to transfer accused to the National Center for Mental Health, after
refusal to answer any question.
Initial examination at NCMH revealed Fernando as suffering from schizophrenia. He was
detained and medicated at the hospital. He was discharged after 2 years, and recommitted at the
provincial jail after being found fit to face charges.

At the trial, it was established that the accused was legally married to the victim, and their
union resulted in 7 children. He worked as a seaman for 16 years, and thereafter started a hardware
store business. His venture failed, and he lost his entire fortune to cockfighting. Fernando, his wife,
and the children, were forced to move in with his mother-in-law ( Avelina Mirador), because he could
no longer support his family. Lillia was also heavily pregnant with their 8th child, and was about to
give birth.

On Sept. 3, 1993, Fernando and Lillia had because of jealousy. He was accusing her of
infidelity, and in the heat of the fight, stabbed her in front of the children. The children were heard
shouting and crying, and were brought out of the house by Avelina Mirador’s nephew. She mentions
seeing the accused emerge from the house, with a bolo. She declares no observation of anything
peculiar about accused before the event, nor does she know of any reason why he killed Lillia,
because she never saw the two engage in any argument while living with her. Accused declares no
recollection of any relevant events. He was sentenced with penalty of reclusion perpetua. Accused
appealed, insisting his criminal act was involuntary.

ISSUE: Whether or not evidence adduced by the defense is sufficient to establish appellant’s
insanity, which would be a basis for being free from criminal liability.

HELD: No. Philippine Courts have established a stringent criterion for insanity. To be exempting, it is
required that: (1) there must be a complete deprivation of intelligence in committing the act; (2) he
acted without the least discernment because there is complete absence of power to discern; (3) or
that there is total deprivation of will.

Appellant was diagnosed to be suffering from schizophrenia AFTER he killed his wife.
Record is also bereft of even a single account of abnormal or bizarre behavior prior to event.

Evidence of insanity after the fact may be accorded weight only if there is also proof of abnormal
behavior immediately before or simultaneous to commission of crime. Appellant failed to establish
convincing evidence of alleged insanity at the time of killing his wife.
People v. Robios, G.R. No. 138453, 29 May 2002, 382 SCRA 581

FACTS: Melencio Robios was found guilty with the complex crime of parricide with unintentional
abortion and was sentenced of death. May 31, 1995, he was accused of killing his pregnant wife.
March 25, 1995 Lorenzo Robios, son of Melencio heard his parents quarreling and saw Melencio stab
her mom Lorenza with an 8-inch double bladed knife on the right shoulder. On the same day,
Benjamin, brother of Lorenza reported that Melencio has also killed their uncle. Benjamin knowing
what Melencio did to her sister, went to her sister’s house and when he was 150m away, saw Melencio
and the latter shouted “Its good you would see how your sister would die.” Benjamin sought the help
of the police.
SPO1 saw Melencio embracing her wife uttering the words “I will kill myself, I will kill myself”. Lorenza,
who was lying on her back and facing upward, was no longer breathing. She appeared to be dead.
Appellant dropped the knife which was taken by SPO3 Martin. Appellant tried to resist the people who
held him but was overpowered. The police, with the help of the barangay officials present, tied his
hands and feet with a plastic rope. However, before he was pulled away from the body of his wife and
restrained by the police, appellant admitted to Rolando Valdez, a neighbor of his and a barangay
kagawad, that he had killed his wife, showing him the bloodstained knife.
Special report showed that Lorenza Robios was six (6) months pregnant. She suffered 41 stab wounds
on the different parts of her body and that the appellant was under the influence of alcohol and also
stabbed himself.
Melencio admitted that she killed his wife but wish to be exempted of his criminal liability invoking
insanity. His son testified that Melencio saw someone in their house that wanted to kill him. A nurse
said that Melencio “isolated himself, laging nakatingin sa malayo, rarely talked, just stared at her and
murmured alone”. A detention prisoner witnessed the appellant usually refusing to respond in the
counting of prisoners. Sometimes, he stayed in his cell even if they were required to fall in line in the
plaza of the penal colony. And another prisoner said that accused sometimes was lying down, sitting,
looking, or staring on space and without companion, laughing and sometimes crying. And Melencio
said that he did not know that he was charged for the crime of parricide with unintentional abortion. He
could not remember when he was informed by his children that he killed his wife. He could not believe
that he killed his wife

ISSUE: Can he be exempted on the grounds of insanity? What is the proper penalty for him?

HELD:
1. Testimonies from both prosecution and defense witnesses show no substantial evidence that
appellant was completely deprived of reason or discernment when he perpetrated the brutal
killing of his wife. The fact that appellant admitted to responding law enforcers how he had just
killed his wife may have been a manifestation of repentance and remorse -- a natural sentiment
of a husband who had realized the wrongfulness of his act. His behavior at the time of the killing
and immediately thereafter is inconsistent with his claim that he had no knowledge of what he
had just done and he was not insane during the commission of the crime.
2. Since appellant was convicted of the complex crime of parricide with unintentional abortion, the
penalty to be imposed on him should be that for the graver offense which is parricide and
punishable with reclusion perpetua to death.
People v. Opuran, G.R. Nos. 147674-75, 17 March 2004, 425 SCRA 654

FACTS
On the night of November 19, 1998, Anacito Opuran went to the front of the house of the Herreras
where Bambi's brother, a certain Jason Masabang were sitting and opposite them Allan Dacles was
lying on a bench.The accused then suddenly stabbed Allan Dacles with a bladed weapon called as
pisao. The victim died due to a fatal wound in the upper right lobe of his lung and his bronchial
vessels. Dacles, with the support of Bambi's brother and Jason, managed to run inside the house
and locked the doors. When the accused failed to enter the house, he left and stayed in the dark part
of the highway where the other victim was walking going home. Tomas Baclas, a guest of the
victim's wife was about to leave the house when he heard that the accused stabbed someone. He
was standing near the gate of the house when he saw the victim walking towards the house and the
accused hiding in the dark. The accused suddenly stabbed Patrimonio 4 times which caused his
instantaneous death.

Opuran was charged with murder and homicide for killing Patrimonio, Jr. and Dacles, respectively.

During the trial, the accused was presented as a witness and contended that he was at his house at
the time of the incidents and that the police went to arrest him while he was sleeping that night.
While the sister of the victim claimed that Anacito was diagnosed with mental aberration in 1986 and
stopped taking his medicine in 1990. Hearings were postponed by the court to enable the victim to
be examined by an expert. Eventually, the trial court found Anacito Opuran guilty of murder and
homicide.

The mental state of Anacito, as testified to by Dr. Verona, corresponds to the period after the
stabbing incidents. Further, Dr. Verona was certain that Anacito was not grossly insane, but she was
uncertain that Anacito was “unconscious” at the time he stabbed the two victims.

ISSUE: Whether or not the accused was suffering from a mental disorder

RULING:
The stringent standard established in People v. Formigones (87 Phil 658) requires that there be a
complete deprivation of intelligence in committing the act, i.e., the accused acted without the least
discernment because of a complete absence of the power to discern or a total deprivation of the will.
In People v. Rafanan, Jr. (204 SCRA 65), we analyzed the Formigones standard into two
distinguishable tests: (a) the test of cognition—whether there was a “complete deprivation of
intelligence in committing the criminal act” and (b) the test of volition—whether there was a “total
deprivation of freedom of the will.

The testimonial evidence of the defense also attempted to prove the alleged behavioral oddity of
Anacito two to three days prior to the killing.

Tested against the stringent criterion for insanity to be exempting, such deportment of Anacito, his
occasional silence, and his acts of laughing, talking to himself, staring sharply, and stabbing his
victims within a 15-minute interval are not sufficient proof that he was insane immediately before or
at the time he committed the crimes. Such unusual behavior may be considered as mere
abnormality of the mental faculties, which will not exclude imputability. Anacito’s psychiatric history
likewise fails to meet the stringent yardstick established by case law. What it shows is that Anacito
was prescribed thorazine and evadyne, and later an injectable medicine to remedy “his lack of sleep
and noisiness". As the trial court noted, it was never shown that these drugs were for a mental
illness that deprived Anacito of reason.

The records are likewise clear that Anacito was not subjected to treatment from 1991 until 1999.
While Remedios insisted that the medicine prescribed for Anacito ran out of stock allegedly in 1990,
there was no proof that Anacito needed the medicine during that period. In fact, there was no
intimation that he needed the medicine prior to the stabbing incident.

Moreover, as found by the trial court, the results of Dr. Verona’s examinations on Anacito were
based on incomplete or insufficient facts. For one thing, she admitted to have examined Anacito for
only three sessions lasting one to two hours each.

Interestingly, Anacito failed to raise insanity at the earliest opportunity. He invoked it for the first time
in the year 2000 and only after he had already testified on his defenses of alibi and denial. It has
been held that the invocation of denial and alibi as defenses indicates that the accused was in full
control of his mental faculties.

Additionally, the trial judge observed that, during the hearings, Anacito was attentive, well-behaved,
and responsive to the questions propounded to him. Thus, the shift in theory from denial and alibi to
a plea of insanity, made apparently after the appellant realized the futility of his earlier defenses, is a
clear indication that insanity is a mere concoction or an afterthought.
GUILTY!