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 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:

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 police’s doubt of his
mental normalcy
5. Defendant suffered from manic depressive psychosis according to Dr. Joson

Dissenting (Justices Imperial, Diaz and Concepcion):

o The dissenting opinions pose that the accused committed the crime when he was sane, or at least, during a
lucid interval.
o The legal presumption is always in favor of sanity; no positive evidence of accused mental state was
established
o Based on expert testimonies, accused was cured of dementia praecox and later manic depressive psychosis
o 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
o There is a motive of aggression on part of accused is real and positive fact: deceased’s failure to pay
borrowed money