G.R. No.

L-45130 February 17, 1937

The People of the Philippines vs. Celestino Bonoan Y. Cruz

FACTS:

Defendant Celestino Bonoan Cruz was charged with the crim of murder for stabbing Carlos Guison with
a knife, which caused his death after 3 days from the incident. An arraignment for the case was called
however, the defense counsel objected on the ground that the defendant was considered mentally
deranged and was at that time confined at the Psychopatic Hospital. Several months had passed when
assistant alienist Dr. Jose Fernandez reported to the court that the defendant may be released or
discharged from the hospital. The lower court had found Bonoan guilty and sentenced him for life
imprisonment or reclusion perpetua after trial. However, the defense appealed to this, claiming that the
lower court made mistakes in finding the defendant suffering only from dementia 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:

Whether or not Bonoan was insane at the time of his commission of the crime

Whether or not the defendant was criminally liable.

RULING:

Yes. Bonoan was insane at the time of the commission of his crime. The Court found the accused
demented at the time of his commission to the crime, which consequently exempts him from criminal
liability and orders for his confinement in San Lazaro Hospital or other hospital that were necessary for
the insane. The given decision of the court was supported by the following evidences:

1. The accused was already confined long before his commission of the offense in the insane
department of San Lazaro Hospital and was diagnosed with dementia. Thus, recurrence of
ailments were not entirely lacking of scientific foundation.
2. It shall be noted that persons who suffers from dementia are disqualified from legal
responsibility due to fact that they have no control of their acts. Its symptoms have similarity to
manic depression psychosis.
3. According to Dr. Francisco, after 4 days of the commission of the act, the defendant had an
insomnia attack, a symptom leading to dementia praecox.
4. On the same day of the crime and the arrest of the accused, he was sent to the Psychopatic
hospital, indicating that the police’s doubt his mental normalcy.
5. According to another expert, Dr. Joson, the defendant suffered from manic depressive
psychosis.

Thus, the defendant was not criminally liable, nor he was sane at the time of the commission of the
crime. Bonoan may have been conscious with his acts however, provided the fact that he was
hospitalized before the commission of the crime, it may have had a psychological impact on his behavior
or acts.