Short Name:

US v. Vaquilar

Long Name:

The United States v. Evaristo Vaquilar

FACTS
[undated]

[undated]

The appellant, Evaristo Vaquilar, was charged in two separate

informations with parricide, one for the killing of his wife and the other
for the killing of his daughter. He was sentenced to life imprisonment, to
indemnify the heirs, to the accessory penalties, and to the payment of the
costs in each case. From this judgment, he appealed. The two cases have
been submitted to this court together.
The appellant was proven to have killed his wife and daughter in the
manner charged and to have wounded other persons with a bolo. The
commission of the crimes is not denied, but several witnesses were
introduced in his behalf, testifying that the defendant appeared to them to
be insane at and subsequent to the commission of the crimes. They also
testified that he had been complaining of pains in his head and stomach
before the killing.
Martin Agustin, witness for the prosecution, testified that he
heard the appellant, his uncle, make a noise, then enter the
house to see the appellant kill his wife and daughter, that he
was cut personally, that there was no disagreement between
appellant and his family, and that on the morning, the
appellant felt pains in his head and stomach. His eyes were
allegedly very big and he was allegedly crazy as he would
not have killed his family otherwise.
Diego Agustin, witness for the defense, helped Martin
apprehend the accused, that the appellant himself used to say
he felt pains in his head and stomach, and he looked like a
madman because he cut everybody at random without
paying attention as to who it was
Alejandra Vaquilar testified that her brother had the
headache and stomach pains five days prior to the crimes,
and he looked sad at the time but he pursued her, and he
must have been crazy because he cut her.
Estanislao Canaria testified that he observed the inmate and
that sometimes, his head is not right, he does not say
anything at all, and he often cries aloud, asking what they are
doing to him and calling them beasts
The health officer who examined the wounded parties and
found that the wife had five mortal wounds in the head, and
the daughters skull was split through from one side to the
other. He did not notice whether defendant was suffering
from any mental derangement or not.

ISSUES
1. WON the defendant-appellant was mentally unsound at the time the parricides were committed.

RULING
1. No. There is a vast difference between an insane person and one who has worked himself up into
such a frenzy of anger that he fails to use reason in what he does. The popular meaning of the
word crazy is not synonymous with the legal terms insane, non compos mentis,
unsound mind, idiot or lunatic. In this case, the witnesses conception of crazy is the
doing of some act by a person which an ordinary rational person would not think of doing.
Likewise, the conduct of appellant when confined in jail is not inconsistent with the actions of
sane persons, as remorse may be sufficient to make the appellant cry out those words. In People v.
Mortimer, the supreme court distinguishes between passion and insanity, stating that they are two
different things, and whatever indulgence the law extends to persons under provocation does not
exempt them from criminal responsibility. This is affirmed in People v. Foy. Likewise, the
Encyclopedia of Law and Procedure says that mere mental depravity or moral insanity, where the
person is mentally same but his moral system is perverted, does not exempt one from criminal
responsibility. Likewise, in US v. Carmona, in the absence of proof that the defendant has lost his
reason, he is presumed sane as it is improper to assume that he is mentally unsound to relieve him
of his criminal burden. Insanity can only be a defense if it is apparent that the person is insane
andthat the offense was the direct consequence of his insanity.
As the appellants conduct is more consistent with that of an enlarged criminal, and it not having
been satisfactorily shown that he was of unsound mind, and the facts charged been proven, and the
penalty in accordance with law, the judgments appealed from are AFFIRMED. Costs against
appellant.