People v.

Taneo moral perversion may lead a man to commit a crime

without a real motive but just for the sake of committing
PEOPLE v. TANEO [58 Phil. 255 (1933)]
it. In the case at hand, the court found not only lack of
motives for the defendant to voluntarily commit the acts
complained of (read: he loved his wife dearly, he tried to
Facts: Potenciano Taneo and his wife lived in his parent's attack his father in whose house the lived and the guests
house in Dolores, Ormoc. On January 16, 1932, a fiesta whom he invited), but also motives for not committing
was being celebrated in the said barrio and guests were the acts.
entertained in the house, among them were Fred Tanner
and Luis Malinao. Early that afternoon, Potenciano went Dr. Serafica, an expert witness in the case, stated that
to sleep and while sleeping, he suddenly got up, left the considering the circumstances of the case, the defendant
room bolo in hand and, upon meeting his wife who tried acted while in a dream, under the influence of a
to stop him, wounded her in the abdomen. He also hallucination and not in his right mind.
attacked Fred and Luis and tried to attack his father, after
The wife's wound may have been inflicted accidentally.
which, he wounded himself. Potenciano's wife, who was
The defendant did not dream that he was assaulting his
7 months pregnant at that time, died five days later as a
wife, but that he was defending himself from his
result of the wound.
enemies.
The trial court found Potenciano guilty of parricide and
Judgment: defendant not criminally liable for the
was sentenced to reclusion perpetua.
offense. It was also ordered that he be confined in the
It appears from the evidence that the day before the government insane asylum and will not be released until
commission of the crime, the defendant had a quarrel the director thereof finds that his liberty would no longer
over a glass of "tuba" with Collantes and Abadilla, who constitute a menace
invited him to come down and fight. When he was about
to go down, he was stopped by his wife and his mother.
On the day of the commission of the crime, it was noted
that the defendant was sad and weak, had a severe
stomachache that's why he went to bed in the early
afternoon. The defendant stated that when he fell
asleep, he dreamed that Collantes was trying to stab him
with a bolo while Abadila held his feet. That's why he got
up and it seemed to him that his enemies were inviting PEOPLE v. BONOAN [64 Phil. 87 (1937)]
him to come down; he armed himself with a bolo and left
the room. At the door, he met his wife who seemed to
say to him that she was wounded. Then, he fancied Nature: Appeal from a judgment of the CFI of Manila
seeing his wife really wounded and in desperation
wounded himself. As his enemies seemed to multiply
around him, he attacked everybody that came his way.
Facts:

12 Dec. 1934 - Celestino Bonoan met Carlos Guison on

Issue: WON defendant acted while in a dream.
Ratio: Yes. The defendant acted while in a dream & his
acts, therefore, werent voluntary in the sense of
entailing criminal liability.
The apparent lack of motive for committing a criminal act
does not necessarily mean that there are none, but that
simply they are not known to us. Although an extreme
Avenida Rizal near a barbershop close to Tom's Dixie
Kitchen. Francisco Beech, who was at the time in the
barbershop, heard Bonoan say in Tagalog, "I will kill you."
Beech turned around & saw Bonoan withdrawing his
right hand, w/c held a knife, from the side of Guison who
said, "I will pay you," but Bonoan simply replied saying
that he would kill him & then stabbed Guison 3 times on
the left side. The incident was witnessed by policeman
Damaso Arnoco. Bonoan was arrested on the day itself.
Bonoan admitted to stabbing Guison. Guison was taken
to PGH where he died 2 days later.
5 January 1935 - Prosecuting attorney of Manila filed an
information charging Celestino Bonoan with the crime of
murder.
16 January 1935 - Bonoan's 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. The court issued and order
requiring the Director of the hospital to report on
Bonoan's mental condition. A report was rendered by Dr.
Toribio Joson.
23 March 1935 - the case was called for arraignment
again, the defense objected and again the court filed
another order requiring the doctor who examined
Bonoan to appear in court to report on Bonoan's mental
condition.
26 March 1935 - Dr. Toribio appeared before the court
for the inquiry. The court issued another order asking to
summon other doctors from the hospital and to put
Bonoan under another doctor, Dr. Jose Fernandez, for
closer observation. Dr. Fernandez filed his report on 11
June 1935.
28 June 1935 the case was called again, Dr Fernandez
showed up in court and reported that Bonoan was still
not in a condition to defend himself.
21 January 1936 - Dr. Fernandez reported to the court
that
Bonoan could be discharged from the hospital and
appear for trial as he was "considered a recovered case."
27 February 1936 - Bonoan was arraigned and pleaded
"not guilty" and the trial was held. To prove motive and
mental normalcy of Bonoan the prosecution called on
Damaso Arnoco who testified that the reason for
Bonoan's attack was that Guison owed him P55 and
would not pay him back. Bonoan had bought the knife
with which he stabbed Guison for 50 centavos and had
been waiting 2 days to kill him. He acquired this
information when he arrested and questioned Bonoan.
Bonoan was charged with the murder of Carlos Guison,
and sentenced him to life imprisonment and to pay P1K
to indemnify the heirs of Guison.
The defendant appealed the case and his counsel cited
that the lower court had erred in finding that Bonoan had
dementia intermittently and not immediately prior to
the commission of the offense, in finding that the
accused did not show any abnormality either in behavior,
action, language, appearance, or action that he was
mentally deranged, in finding that the burden of proof
lay in the defendant to prove that he was mentally
deranged at the time of the crime, and in not acquitting
Bonoan.
Issue: WON Bonoan was insane at the time of the
commission of the crime.
Held: Yes. There are 3 different theories used
Insanity as a defense in a confession and avoidance and
as such must be proved beyond reasonable doubt. Proof
of insanity at the time of committing the criminal act
should be clear and satisfactory in order to acquit the
accused on the ground of insanity. (Philippines uses this)
That an affirmative verdict of insanity is to be governed
by preponderance of evidence, and in this view, insanity
is not to be established beyond a reasonable doubt.
Prosecution must prove sanity beyond a reasonable
doubt.
When a defendant in a criminal case interposes the
defense of mental incapacity, the burden of establishing
the fact rests upon the defendant. To prove insanity the
evidence must be clear and convincing. The courts need
to distinguish insanity in law from passion or eccentricity,
mental weakness or mere depression resulting from
physical ailment. In the separate reports given by Dr.
Toribio Joson and Dr. Fernandez they both diagnosed
Bonoan to be unstable, stating that "he will always have
troubles and difficulties with this world of realities."
Bonoan was diagnosed with dementia praecox which is a
mental disease that disqualifies a person from legal
responsibility for his actions. In these people homicidal
attacks are common because of the delusions that they
are being interfered with or that their property is being
taken. The court was of the opinion that Bonoan was
demented at the time he perpetrated the serious offense
charge with and that consequently he is exempt from
criminal liability.
Judgment: Judgment of the lower court REVERSED.
Defendant appellant ACQUITTED but to be kept in
confinement in the San Lazaro Hospital or any other
hospital for the insane.
Imperial, dissenting: "The dissenting opinions, in
establishing the conclusion that the accused was then in
the possession of his mental faculties or, at least, at a
lucid interval, are based on the fact admitted by the
parties and supported by expert testimony, that the
accused before the commission of a crime, had been
cured of dementia praecox and later of manic depressive
psychosis." The inference of the majority that the
accused was insane is not sufficiently supported by
evidence. No attention was given to the decision of the
judge who originally tried the case, which should have
been done because he was able to observe Bonoan, the
witnesses, the evidence and the testimonies. This court
generally gives importance to the conclusions drawn by
the judge who tried the case in first instance unless there
is a clear contradiction in the evidence and the decision,
which is not the case here.
Diaz, dissenting: The appellant committed the crime
when he was sane or at least during a lucid interval. He
had motive to kill Guison [55php], as clearly stated by the
arresting police officer. The law presumes that everyone
is sane, and insanity is an exception, to be established by
clear proof and it is not usually permanent. There is no
evidence or record that can prove that Bonoan was
insane at the time he committed the crime, or that he
was continuing to suffer from insanity from the date of
the commission of the crime. Where it is shown that the
defendant experiences lucid intervals, the crime is
assumed to have been committed during one of them,
unless proven otherwise.
Concepcion, dissenting: There is no evidence or record to
prove that Bonoan was insane at the time he committed
the crime, and there were no records to show that he
had suffered a relapse of the condition he had sought
treatment for at the San Lazaro hospital years before the
crime was committed. Bonoan had been sane for 9 years
[or at least "socially adjustable"]. The attack of insomnia
before the event is not clear proof that he was insane or
suffering a bout with insanity at the time of the crime, it
merely presents a possibility, and the innocence to the
accused cannot be based on a mere possibility. The
accused when questioned by the police immediately
after the crime did not exhibit insane behavior. It cannot
be said that Bonoan stabbed Guison because of a
hallucination because Guison actually owed him money
and this was confirmed by the fact of his saying "I am
going to pay you" before he was stabbed. This shows the
motive for aggression [vengeance]
PEOPLE v. DUNGO [199 SCRA 860 (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 JrInsanity
FACTS:
On February 27, 1976, complainant Estelita Ronaya who
was then only fourteen years old was hired as a
househelper by themother of the accused. The accused
Policarpio Rafanan and his family lived with his mother in
the same. Policarpio was then marriedand had two
children.On March 16, 1976, in the evening, after dinner,
Estelita Ronaya was sent by the mother of the accused to
help in theirstore which was located in front of their
house. Attending to the store at the time was the
accused. At 11:00 o'clock in the evening,the accused
called the complainant to help him close the door of the
store and as the latter complied and went near him,
hesuddenly pulled the complainant inside the store and
said that they should have intercourse, Ronaya refused.
The accused held abolo and pointed it to the throat
of the complainant threatening her with said bolo should
she resist. He then raped Ronaya in spiteof her
resistance and struggle. After the sexual intercourse, the
accused cautioned the complainant not to report the
matter to hermother or anybody in the house, otherwise
he would kill her. In the evening of March 17, 1976, the
family of the accused learnedwhat happened that
night.The principal submission of appellant is that he was
suffering from a metal aberration characterized as
schizophrenia whenhe inflicted his violent intentions
upon Estelita. The trial court suspended the trial and
ordered appellant confined at the NationalMental
Hospital in Mandaluyong for observation and treatment.
In the meantime, the case was archived. Appellant was
admittedinto the hospital on 29 December 1976 and
stayed there until 26 June 1978.On the last report dated
26 June 1978, appellant was described as behaved,
helpful in household chores and no longertalking while
alone. He was said to be "fairly groomed" and "oriented"
and as denying having hallucinations. The report
concludedthat he was in a "much improved condition"
and "in a mental condition to stand court trial."Trial of
the case thus resumed. The defense first presented Dr.
Arturo Nerit who suggested that appellant was sick one
ortwo years before his admission into the hospital, in
effect implying that appellant was already suffering from
schizophrenia when heraped complainant.
ISSUE
: Whether or not the reason of insanity in this case is
sufficient to relieve himself of criminal liability through
exemptingcircumstance.
HELD:
NO
RATIO:
The Supreme Court of Spain held that
in order that this exempting circumstance may be taken
into account, it is necessary that there be a complete
deprivation of intelligence in committing the act,that
is ,that theaccused be deprived of reason;that therebeno
responsibility for his own acts;that theacts without the
least discernment; or that there be a total deprivation of
freedom of the will. F or this reason, it was held that the
imbecility or insanity at the time of the commission of
the act should absolutely deprivea person of intelligence
or freedom of will, because mereabnormality of his
mental faculties does not exclude imputability. The
allegation of insanity or imbecility must be clearly
proved. Without positive evidence that the defendant
hadpreviouslylost his reasonor wasdemented, a few
moments prior to or during the perpetration of the
crime, it will be presumed that he was in a normal
condition. Acts penalized by law are always reputed to
be voluntary,and it is improper to conclude that a
personacted unconsciously, in order to relieve him from
liability, on the basis of his mental condition, unless his
insanity and absence of willare proved.Schizophrenia
pleaded by appellant has been described as a chronic
mental disorder characterized by inability to
distinguishbetween fantasy and reality, and often
accompanied by hallucinations and delusionsIn the
findings of the case, testimonies negates complete
destruction of intelligence at the time of commission of
the actcharged which, in the current state of our caselaw,
is critical if the defense of insanity is to be sustained.
The fact that appellant Rafanan threatened complainant
Estelita with death should she reveal she had been
sexually assaulted by him, indicates, to the mind of the
Court, that Rafanan was aware of the reprehensible
moral quality of that assault.
In any case, as already pointed out, itiscomplete loss of
intelligencewhich must be shown if the exempting
circumstance of insanity is to be found.The law presumes
every man to be sane. A person accused of a crime has
the burden of proving his affirmative allegation
of insanity. Here, appellant failed to present clear and
convincing evidence regarding his state of mind
immediately before and duringthe sexual assault on
Estelita. It has been held that inquiry into the mental
state of the accused should relate to the
periodimmediately before or at the very moment the act
is committed. Appellant rested his case on the
testimonies of two (2) physicianswhich, however, did not
purport to characterize his mental condition during that
critical period of time. They did not specificallyrelate to
circumstances occurring on or immediately before the
day of the rape. Their testimonies consisted of broad
statementsbased on general behavioral patterns of
people afflicted with schizophrenia

People vs. Madarang
G.R. No. 132319. May 12, 2000Ponente: Puno, J.Topic:
Insanity/Imbecility: Basis of Exception
FACTS:Fernando Madarang was charged with parricide
for killing his wife Lillia Madarang. Herefused to enter a
plea during arraignment,and so was entered as not
guilty in accordance tothe rules of court. Counsel for the
accused manifested that his client had been
observedexhibiting abnormal behavior. Court decided to
transfer accused to the National Center forMental
Health, after refusal to answer any question.Initial
examination at NCMH revealed Fernando as suffering
from schizophrenia. He wasdetained and medicated at
the hospital. He was discharged after 2 years, and
recommitted atthe provincial jail after being found fit to
face charges.At the trial, it was established that the
accused was legally married to the victim, andtheir union
resulted in 7 children. He worked as a seaman for 16
years, and thereafter started ahardware 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
( AvelinaMirador), because he could no longer support
his family. Lillia was also heavily pregnant withtheir 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
wereheard shouting and crying, and were brought out of
the house by Avelina Miradors nephew.She mentions
seeing the accused emerge from the house, with a bolo.
She declares noobservation of anything peculiar about
accused before the event, nor does she know
of anyreason why he killed Lillia, because she never saw
the two engage in any argument while livingwith her.
Accused declares no recollection of any relevant events.
He was sentenced withpenalty 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
sinsanity, 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 todiscern; (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. Appellantfailed
to establish convincing evidence of alleged insanity at the
time of killing his wife
People vs. Robios
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 sisters
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: 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.

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.