People vs.

Ambal
GR NO. L-52688 OCT. 17, 1980
100 SCRA 325
FACTS: Honorato Ambal was married with Felicula for 15 yrs. She appeared to be a shrew and neglectful
wife. She stayed away from the conjugal home at times. He killed her when the latter failed to buy a
medicine for Ambal who was afflicted with influenza. The two engaged in a heated altercation. Felicula
told her husband that it would be better if he were dead. That remark infuriated Ambal and impelled him
to attack his wife.
He went to the barangay captain and informed that he killed his wife. After making that oral confession,
Ambal took a pedicab, went to the municipal hall and surrendered to a policeman.
During the trial, he pleaded not guilty and, thru his counsel de oficio, the defense of Ambal was insanity.
Dr. Balbas stated during trial: Before the commission of the crime, he was normal. After the commission
of the crime, normal, but during the commission of the crime, that is what we call Psychosis due to short
frustration tolerance.
The Court of First Instance of Camiguin convicted him of parricide, sentencing him to reclusion perpetua
and ordering him to pay an indemnity of Php12,000 to the heirs of his deceased wife, Felicula Vicente-
Ambal.
ISSUE: Whether or not Ambal was insane and is not guilty of the crime of parricide.
RULING: Art. 12 of the Revised Penal Code exempts from criminal liability an imbecile or an insane
person unless the latter has acted during a lucid interval. The law presumes that every person is of sound
mind, in the absence of proof to the contrary (US vs. Martinez, 34 Phil 305). The law always presumes all
acts to be voluntary. It is improper to presume that acts were executed unconsciously. In order that
insanity may be taken as an exempting circumstance, there must be complete deprivation of intelligence
in the commission of the act or that the accused acted without the least discernment. Mere abnormality of
his mental faculties does not exclude imputability.
Ambal is guilty of parricide with the mitigating circumstance of voluntary surrender to the authorities.
Article 246 of the Revised Penal Code punishes parricide with reclusion perpetua to death. The lesser
penalty should be imposed because of the presence of one mitigating circumstance and that absence of
aggravating circumstance
PEOPLE v. FORMIGONES
November 29, 1950 (G.R. No. L-3246)
PARTIES:
plaintiff-appellee: THE PEOPLE OF THE PHILIPPINES
defendant-appellant: ABELARDO FORMIGONES
FACTS:
From November to December 1946, defendant Abelardo Formigones together with his wife Julia Agricola,
and his five children lived in the house of his half-brother, Zacarias Formigones to find employment as
harvesters. One afternoon, the accused, without any previous quarrel or provocation whatsoever, took his
bolo from the wall of the house and stabbed his wife at the back, the blade penetrating the right lung
which latter caused her death. When she fall ont he ground the defendant carried her up the house, laid
her on the floor of the living room and then lay down beside her. He was convicted of parricide and was
sentenced to prison. The defendant entered a plea of not guilty. His counsel presented testimonies of two
guards of the provincial jail where defendant was confined. They said that he behaved like an insane
person, that sometimes he would remove his clothes in front of others, would not take a bath, and
remained silent and indifferent to his surroundings. His counsel claimed that e is an imbecile therefore
exempt from criminal liability. Dr. Francisco Gomez told that Abelardo was suffering only from
feeblemindedness and not imbecility and that he could distinguish right from wrong. An imbecile so as to
be exempt from criminal liability, he must be deprived completely of reason or discernment and freedom
of the will at the time of committing the crime.

ISSUE: WON the defendant who is suffering from feeblemindedness is exempt from criminal liability.
HELD:
No. In order that an 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 the accused be deprived of reason;
that there be no responsibility for his own acts; that he acts without the least discernment; that there be a
complete absence of the power to discern, or that there be a total deprivation of freedom of the will. As to
the strange behaviour of the accused during his confinement, assuming that it was not feigned to
stimulate insanity, it may be attributed either to his being feebleminded or eccentric, or to a morbid mental
condition produced by remorse at having killed his wife. He could distinguish right from wrong.
PEOPLE V BONOAN
Imbecility
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 defendants complete record of
mental condition from the hospital and defendants 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 defendants insanity and finding accused guilty.
Issue:
W/N 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 polices 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: deceaseds failure to
pay borrowed money