UP Law F2021 People v.

Bonoan
Medical Jurisprudence Par. 1, Art. 12, RPC 1937 Laurel

SUMMARY

FACTS

 On 12 Dec 1934, defendant Bonoan met the deceased Carlos Guison on Avenido Rizal
near a barbershop.
 Witness Francisco Beech, who was at the barbershop, heard Bonoan say in Tagalog, “I
will kill you.”
 Beech turned around and saw the accused withdrawing his right hand, which held a
knife, from the side of Guison who said, also in Tagalog, "I will pay you.”
o Bonoan replied saying that he would kill him and then stabbed Guison thrice on
the left side.
 The assault was witnessed by policeman Damaso Arnoco who rushed to the scene and
arrested Bonoan and took possession of the knife.
 On 5 Jan 1935, the prosecuting attorney filed an information charging defendant-
appellant Celestino with the crime of murder.
o Committed in Manila
o With evident premeditation and treachery
o Victim: Carlos Guison
o Attack, assault, stab on different parts of body with a knife
o One stab wound at the right epigastric region penetrating 1 cm. into the superior
surface of the right lobe of the liver; and 3 non-penetrating stab wounds located
respectively at the posterior and lateral lumbar region, and left elbow
 Defense counsel object to the arraignment claiming defendant was mentally deranged
and was at a time confined in the Psychopathic hospital
 Court ordered the Director of the Hospital to render a report on the mental condition
 Dr. Fernandez, assistant alienist of the Hospital rendered his report and testified in
court that the accused was not in a condition to defend himself.
 The case was suspended indefinitely.
 On 21 Jan 1936, Dr. Fernandez reported to the court that the accused “had recovered
from the diseased.
 On 27 Feb 1936, the accused was arraigned and pleaded “not guilty.”
 The TC found him guilty and sentenced him to life imprisonment.
 The killing was admitted.
 The defense set up was insanity.

RATIO

W/N defendant-appellant Bonoan was insane at the time of the commission of the crime.
Yes. There are 3 different theories in the US on the legal presumption and the kind of quantum
evidence required on the question of insanity as a defense:
1st: insanity as a defense in a confession and avoidance and as such must be proved beyond a
reasonable doubt
2nd: an affirmative verdict of insanity is to be governed by a preponderance of evidence, and in
this view, insanity is not to be established beyond a reasonable doubt
3rd: the prosecution must prove sanity beyond a reasonable doubt (liberal view)
In the Philippines, the first and stricter view is followed: the burden, to be sure, is on the
prosecution to prove beyond a reasonable doubt that the defendant committed the
crime, but sanity is presumed, and when a defendant in a criminal case interposes the
defense of mental incapacity, the burden of establishing that fact rests upon him.
Has there been presented sufficiently convincing evidence, direct or circumstantial, to a degree
that satisfies the judicial mind that the accused was insane at the time of the perpetration of
the offense?

In order to ascertain a person's mental condition at the time of the act, it is permissible
to receive evidence of the condition of his mind a reasonable period both before and
after that time. Direct testimony is not required nor are specific acts of derangement essential
to establish insanity as a defense. Mind can only be known by outward acts. Thereby, we
read the thoughts, the motives and emotions of a person and come to determine whether these
acts conform to the practice of people of sound mind. To prove insanity, therefore,
circumstantial evidence, if clear and convincing, suffice.

The State should guard against sane murderers escaping punishment through a general plea of
insanity. In the case at bar, however, the Court is not concerned with connecting two or more
attacks of insanity to show the continuance thereof during the intervening period or periods
but with the continuity of a particular and isolated attack, beginning with the demonstration of
symptoms thereof prior to the commission of the crime charged, and ending with a positive
diagnosis of insanity immediately following the commission of the act complained of.

The ff. are considerations that have weighed heavily upon the minds of the majority:
a. During the periods from April 11 to April 26, 1922, and from January 6 to January 10,
1926, was confined in the insane department of the San Lazaro Hospital suffering from a
disease diagnosed as dementia praecox. Although long before the commission of the
offense on December 12, 1934, this circumstance tends to show that the recurrence of
the ailment at the time of the occurrence of the crime isn’t entirely lacking any
rational scientific foundation.
b. All persons suffering from dementia praecox are clearly to be regarded as having mental
disease to a degree that disqualifies them for legal responsibility for their actions.
According to Dr. Domingo, chief alienist of the Hospital, the symptoms of dementia
praecox, in certain periods of excitement, are similar to those of manic depressive
psychosis and, in either case, the mind appears "deteriorated" because, "when a
person becomes affected by this kind of disease, either dementia praecox or manic
depressive psychosis, during the period of excitement, he has no control whatever
of his acts." Even if viewed under the general medico- legal classification of manic
depressive insanity, "it is largely in relation with the question of irresistible
impulse that forensic relations of manic actions will have to be considered. There
is in this disorder a pathologic lessening or normal inhibitions and the case with
which impulses may lead to actions impairs deliberations and the use of normal
checks to motor impulses."
c. Four days before the crime was committed, the defendant had “an attack of insomnia,”
which is one of the symptoms of, and may lead to dementia praecox.
d. Defendant was arrested on the same day of the crime, and although attempts were
made by detectives to secure a statement from him, he was sent by the police to the
Psychopathic Hospital the day after. This is an indication that the police themselves
 doubted the mental normalcy of the accused.
e. According to the report, made within the 1st month of treatment, by Dr. Joson, the
alienist in charge, the defendant was suffering from a form of psychosis called manic
depressive psychosis. Some things mentioned in the report:
o The patient is underactive, staying most of the time in his bed with his eyes
closed and practically totally motionless. At other times, however, but on very
rare occasions and at short intervals he apparently wakes up and then he walks
around, and makes signs and ritualistic movements with the extremities and
other parts of the body.
o Usually the patient is speechless, can't be persuaded to speak, and would not
answer in any form the questions propounded to him. Very often he is seen with
his eyes closed apparently praying as he was mumbling words but would not
answer at all when talked to.
o Patient is usually apathetic and indifferent, but at times he looks anxious and
rather irritable.
o During the periods that he was accessible he was found oriented as to place and
person but he did not know the day or the date.
o The patient states that during the nights that he could not sleep he could hear
voices telling him many things.
o On one occasion, he told the examiner that he could not talk in his 􏰄rst day in the
hospital because of a mass he felt he had in his throat. He sometimes thinks that
he is already dead and already buried in the La Loma Cemetery.
o He has a fairly good grasp of general information.
o At his fairly clear periods he stated that he might have been insane during his
􏰄rst days in the hospital, but just during the interview on January 14, 1935, he
felt fairly well. Insight and judgment were, of course, nil during his stuporous
condition.

The prosecution presented policeman Damaso Arnoco to prove premeditation and, indirectly,
mental normalcy of the accused at the time of the commission. Damaso testified that upon
arrest, defendant said that the deceased owed him Php55 and would not pay. He bought a knife
for 55centavos and that for 2 days, he had been watching Guison for 2 days in order to kill him.

The SC said that such kind of evidence is not necessarily proof of the sanity of the accused
during the commission of the offense because that in the type of dementia praecox, "the crime
is usually preceded by much complaining and planning. In these people, homicidal
attacks are common, because of delusions that they are being interfered with sexually or
that their property is being taken."

FALLO

In view of the foregoing, we are of the opinion that the defendant-appellant was demented at
the time he perpetrated the serious offense charged in the information and that consequently
he is exempt from criminal liability. Accordingly, the judgment of the lower court is hereby
reversed, and the defendant-appellant acquitted, with costs de oficio in both instances. In
conformity with paragraph 1 of article 12 of the Revised Penal Code, the defendant shall be
kept in confinement in the San Lazaro Hospital or such other hospital for the insane as many be
designated by the Director of the Philippine Health Service, there to remain confined until the
Court of First Instance of Manila shall otherwise order or decree. So ordered.