INSANITY CASES

People vs Taneo

Facts:

On January 16, 1932, a fiesta was being celebrated when Potentiano Taneo went to
sleep. While he was sleeping, he suddenly got up with a bolo in his hand and wounded his
wife, attacked Fred Tanner and Luis Malino, and tried to attack his father which he wounded
himself. As a result of Potentiano’s act, his wife, who was pregnant at that time, died because
of the inflicted wound.

Issue:

Whether or not Potenciano Taneo is liable for the crime of parricide?

Ruling:

No, Potenciano Taneo is not liable for the crime of parricide. According to Article 12
of the Revised Penal Code, insanity exist when there is a complete deprivation of intelligence
in coming the act, that is, the accused is deprived of reason, he acts without the least
discernment, because there is a complete absence of the power to discern, or there is a total
deprivation of freedom of the will. In the case at bar, it appears from the evidence that before
the commission of the crime the defendant was sad and weak which made him to go to his
bed, fell asleep and dreamt. The defendant alleged that when he fell asleep, he dreamt that
Collantes was trying to stab him with a bolo while Abadilla held his feet which made him got
up and left the room. At the door, upon meeting his wife who tried to stop him, wounded her
and also attacked other persons. The act was done without intent, thus Potaneciano Taneo is
not criminally liable for it appears that the act was committed while in a dream which lack or
deprivation of intelligence on the part of the defendant.

People vs. Bonoan

Facts: Celestino Bonoan, the defendant, was charged with the crime of murder for killing
Carlos Guison by stabbing him thrice, which lead to his death. The defense argues that Bonoan
was deranged and was still confined in the Psychotic Hospital, and thus, the lower court found
the defendant guilty of the offense charged. Hence, the appeal of the defense on the ground
that Bonoan suffered dementia and that the lower court made error by not considering such
circumstance.

Issue: Whether or not the defendant was insane at the time of the commission of the crime
charged?

Ruling:
 In proving insanity, the Philippines adapts the first theory presented by the courts in
the United State which states that insanity as a defense in a confession and avoidance and as
must be proved beyond reasonable doubt when the commission of a crime is established,
and the defense of insanity is not made out beyond reasonable doubt, conviction follows.
Relating this in the case at bar, Bonoan is siffering from a form of psychosis, a type of
dementia praecox, homicidal attack is common, because of delusions that he is being
interfered with sexually, or that his property is being taken. During the period of excitement,
such person has no control whatever of his acts. The unlawful acts of Boanoan was due to his
mental disease or defect, producing an irresistible impulse. An irresistible homicidal impulse
was considered embraced in the term insanity. Therefore, the defendant was demented at
the time he perpetrated the serious offense charged and that consequently he is exempt from
criminal liability.

People vs. Rafanan

Facts:
The defendant, Policarpio Rafanan, Jr., is accused of raping Estelita Ronaya was then
only fourteen (14) years old and a house helper of the mother of Rafanan. On March 16, 1976,
at 11:00 o’clock in the evening, Rafanan called the complainant to help him close the door of
the store and suddenly pulled Estelita inside the store and forced himself to her. Although
Estelita refused and struggled, Rafanan threatened her with a bolo and succeeded having
carnal knowledge of her inspite of her resistance and struggle.

Issue: Whether or not reason of insanity will exempt him from criminal liability

Ruling:

No, the court rejected the insanity defense of Rafanan. The law presumes every man
to be sane and the burden of proof is rested upon the defense to prove that the accused was
insane at the time of the commission of the crime. In the case at bar, 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. Therefore, Rafanan is convicted of the crime of
rape with indemnities.

People vs. Robiños

Facts: Melecio Robiños was accused of the crime of parricide with unintentional abortion for
killing his wife, Lorenza Robiños. It was around seven o’clock in the morning when, the fifteen-
year old son of the accused and Lorenza saw them quarrelling in the sala. After hearing such
arguments, Lorenzo, at a distance, saw Melecio Robiños stab his mother, Lorenza, on the right
shoulder and immediately ran to his grandmother’s house to report the incident.
Issue: Whether or not Melecio Robiños may be relieved from criminal liability by reason of
insanity

Ruling:
In order that the exempting circumstance of insanity may be considered, it is
necessary that there be a complete deprivation of intelligence while committing the act, that
is, that the accused be deprived of reason and that he acts without the least discernment; or
that there be a total deprivation of freedom of the will. Accordingly, one who pleads the
exempting circumstance of insanity has the burden of proving it. Hence, appellant who
invoked insanity should have proven that he had already been completely deprived of reason
when he killed the victim. Undoubtedly, the evidence presented by the defense did not
indicate that he had been completely deprived of intelligence or freedom of will when he
stabbed his wife to death. Insanity is a defense in the nature of a confession or avoidance
and, as such, clear and convincing proof is required to establish its existence. Indubitably, the
defense failed to meet the quantum of proof required to overthrow the presumption of
sanity.

People vs. Opuran

Facts: On or about November 19, 1998, Opuran with delibrate intent to kill with treachery,
stab Allan Dacles who was lying on the bench, with the use of a bladed weapon, locally known
as ‘pisao’, inflicting ipon the victim fatal stab wounds on the different parts of his body, which
resulted to his instantaneous death.

Issue: Whether or not Anacito Opuran may use the reason of insanity to relieve from criminal
liability?

Ruling:

Insanity is a condition of the mind, it is not susceptible of the usual means of proof.
He who pleads the exempting circumstance of insanity bears the burden of proving it, for
insanity as a defense is in the nature of confession and avoidance. An accused invoking
insanity admits to have committed the crime but claims that he is not guilty because he is
insane. Relating it to the case at bar, Anacito contends that he was suffering from a psychotic
disorder and was, therefore, completely deprived of intelligence when he committed such
unlawful acts. However, the Court did not find merit in his contention and that he failed to
raise insanity at the earliest opportunity. Additionally, the trial judge observed that, during
the hearings, Anacito was attentive, well-behaved, and responsive to the questions
propounded to him. Therefore, he is presumed sane, and that his conviction is affirmed.

Veradero vs. People

Facts: Maynard Plata and his father Romeo, together with Ronnie Elaydo, went to the police
station to report Verdadero for stealing the fan belt of their irrigation pump. After such
confrontation, Maynard, Romeo and Ronnie made their way home but made a stop in a drug
store. From the drug store, Maynard saw Verdadero stabbing Romeo, and tried to help his
father but Verdadero attempted to attack him as well. Meanwhile, Ronnie after witnessing
the incident, ran towards the police station to seek assistance and the responding police
officer then arrested Veradero.

Issue:
Whether or not Veradero be exempt from criminal liability by reason of insanity

Ruling:

Yes, Veradero may make use of the reason of insanity as a defense. Although the
Regional Trial Court and the Court of Appeal rendered its decision that Veradero is guilty
beyond reasonable doubt, the Supreme Court says otherwise. According to Article 12
paragraph 1 of the Revised Penal Code, an imbecile or an insane person is exempt from
criminal liability, unless the latter had acted during a lucid interval. The defense of insanity or
imbecility must be clearly proved for there is presumption that the acts penalized by law are
voluntary. In the case at bar, Verdero, as early as 1999, was brought to the Psychiatric
Department for treatment, diagnosed with depression, schizophrenia and was confined in the
psychiatric ward due to a relapse. In short, in order for the accused to be exempted from
criminal liability under a plea of insanity, he must be completely deprived of intelligence and
must be manifest at the time or immediately before the commission of the offense. The Court
notes that at the very first opportunity, Verdadero already raised the defense of insanity and
remained steadfast in asserting that he was deprived of intelligence at the time of the
commission of the offense. He no longer offered any denial or alibi and, instead, consistently
harped on his mental incapacity. Therefore, the court acquits him of the crime by reason of
insanity and ordered his confinement in an institution where his mental condition may be
addressed.

MINORITY

People vs. Doqueña

Facts: On or about November 19. 1938, the now deceased Juan Ragojos and one Epifanio
Rarang were playing volleyball in the yard of their school when the Valentin Doqueñs, the
accused, intervened that made Ragojos chase him around the yard and slapped him on the
nape. Doqueña, who is a minor, was prosecuted for homicide for killing Juan Ragojos by
stabbing him in the breast with a knife. The court held that Doqueña acted with discernment
in committing the unlawful act.

Issue: Whether or not Doqueña acted with discernment?

Ruling: Yes, Valentina Doqueña acted with discernment. Discernment means the capacity of
the child at the time of the commission of the offense to understand the difference between
right and wrong and the consequences of the wrongful act. In proving whether he acted with
discernment we must take into consideration not only the facts and circumstances which gave
rise to the act committed by the minor, but also his state of mind at the time the crime was
committed, the time he might have had at his disposal for the purpose of meditating on the
consequences of his act, and the degree of reasoning he could have had at that moment. In
the case at bar, Doqueña was known to be one of the brightest student in said school and was
a captain of a company of the cadet cops and always obtained excellent marks. In the given
information, the court is convinced that he, in committing the crim, acted with discernment
and was conscious of the nature and consequences of his act. Therefore, the accused acted
with discernment and convicted for the crime of homicide.

Ortega vs. People

Facts: Joemar Ortega, who was then 14 years old, was accused of the crime of rape for
allegedly raping AAA, who was about eight (8) years of age. At the time of the promulgation
of judgment, the accused already reach the age of majority. However, Republic Act 9344 (R.A.
No. 9344) or the Juvenile Justice and Welfare Act of 2006, was enacted when the case was
pending and raised the criminal liability from 9 to 15 years old.

Issue: Whether or not R.A. No. 9344 should be applied in the case at bar

Ruling: Yes, such act must be applied in the case at bar. Penal laws are construed liberally in
favour of the accused. In this case, R.A. no. 9344 is most favourable to herein petitioner.
Moreover, it bears stressing that the petitioner was only 13 years old at the time of the
commission of the alleged rape which was duly proven by the petitioner’s mother and
certificate of live birth. That under R.A. no. 9344, he is, therefore, exempted from criminal
liability.

People vs. Lababo

Facts: Benito, Wenefredo and FFF Lababo, were charged for the crime of murder of AAA. That
the accused conspired, confederate and mutually helped each other with deliberate intent to
kill AAA with the use of an unlicensed homemade shotgun and long bolo. On January 26, 2009,
accused-appellants pleaded not guilty to crime charged.

Issue: Whether or not FFF be exempted from criminal liability under the R.A. 9344 or the
Juvenile Justice and Welfare Act

Ruling: The court notes that FFF was a minor at the time of the commission of the offense,
and should benefit from R.A. no. 9344, section 38 which provides for the automatic
suspension of sentence. That instead of pronouncing the judgment of conviction, the court
shall place the child in conflict with the law under suspended sentence, without the need of
application. Provided, however, that suspension of sentence shall still be applied even if the
juvenile is already eighteen (18) years old age or more at the time of the pronouncement of
his/her guilt. A child in conflict with the law is a person who at the time of the commission
of the offense is below 18 years old but not less than 15 years and one day old. Therefore,
FFF may thus be confined in an agricultural camp or any other training facility in accordance
with Section 51 of Republic Act No. 9344.