People v.

Bonoan

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:
Whether or not 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.