G.R. No.

L-37673 March 31, 1933

The People of the Philippine Islands vs. Potenciano Taneo

FACTS:

A fiesta was being celebrated in Ormoc, Leyte on January 16, 1932 where Poteciano Taeneo lives together
with his wife in his parent’s house. On the same date, the defendant slept early due to severe
stomachache. Unknown to him, he got up and left the room with a bolo in hand and upon meeting his
pregnant wife, he attacked her in the abdomen causing her death. Others were also attacked by him
including his own father, Fred Tanner and Luis Malinao, as well as other guests he invited. It was claimed
that he was dreaming when the crime happened however, the trial court had found him guilty of parricide
and sentenced him to reclusion perpetua.

ISSUE:

Whether or not Potencia Taneo is criminally liable.

RULING:

No. The Supreme Court held that the defendant is not criminally liable as he acted while in a dream and
that his acts were not done voluntarily for this is a requisite in entailing criminal liability. The court also
found a lack of motive for the defendant to voluntarily commit the acts complained of as it may be inferred
to the evidence presented that the defendant loved his wife and that there is no reason for him to attack
her, his father, and the guests he himself had invited. Also, a doctor, who was an expert witness in this
case claimed that the defendant was under the influence of hallucination and not in his right mind because
the defendant believes that at the time of the incident, during his dream, he was defending himself from
his enemies which turned out that he was actually hurting his wife. Thus, the defendant was held not
criminally liable however, he was ordered by the court to be confined in an insane asylum.