G.R. No.

L-45130 February 17, 1937

THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee,

vs.
CELESTINO BONOAN Y CRUZ, defendant-appellant.

FACTS:

The prosecuting attorney of the City of Manila filed an information

charging Celestino Bonoan, the defendant-appellant herein, with the
crime of murder of one Carlos Guison.

Bonoan stabbed Guison thrice on his left side which caused the
latter’s death two days afterwards. The defense counsel objected to
the arraignment on the ground that the defendant was mentally
deranged and was at the time confined in the Psychopathic hospital.
Because of this, the court issued orders requiring the director of the
hospital and the hospital’s doctors to render report on the mental
condition of the accused. The doctors reported that Bonoan was
suffering from a disease diagnosed as dementia praecox which is
similar to manic-depressive psychosis.

ISSUE:

Whether or not Bonoan is exempted from the criminal liability.

HELD:

Yes. Insanity as a defense in a confession and avoidance must

be proved beyond reasonable doubt when the commission of the
crime is established. When a defendant in a criminal case interposes
the defense of mental incapacity, the burden of establishing that fact
rests upon him. In this case, the defense interposed that the
defendant was insane at the time he killed the deceased. Prior to the
commission of the offense, he was confined in the insane department
of the San Lazaro Hospital suffering from a disease diagnosed as
dementia praecox. The circumstance tends to show that the
recurrence of the ailment at the time of the occurrence of the crime is
not entirely lacking of any rational or scientific foundation. All persons
suffering from dementia praecox are clearly to be regarded as having
mental disease to a degree that disqualifies them for legal
responsibility for their actions. It is similar to those of manic-
depressive psychosis where the mind appears “deteriorated” because
when a person becomes affected by this kind of disease, during the
time of excitement, he has no control whatever he acts. The accused
was held by the court to be exempted from criminal liability.