People of the Philippines v.

Bonoan
GR No. L-45130, February 17, 1937
Facts:
On December 12, 1934, Celestino Bonoan met with Carlos Guison. A
witness heard Bonoan said I will kill you. Guison said to Bonoan I will pay
you, but Bonoan replied saying that he would kill him and stabbed Guison
thrice on his left side which caused the latters death two days afterwards.
Bonoan was charged with the crime of murder.
When the case was called for arraignment of the accused, the defense
counsel objected to the arraignment on the ground that the defendant was
mentally deranged and was at the time confined in the Psychopathic
hospital. Because of this, the court issued orders requiring the director of the
hospital and the hospitals doctors to render report on the mental condition
of the accused. The doctors reported that Bonoan was suffering form a
disease diagnosed as dementia praecox which is similar to manic depressive
psychosis. On January 21, 1936, Dr. Hernandez of the hospital reported that
the defendant could be discharged from the hospital and appear for trial as
he was considered as recovered case. On February 27, 1936, the accused
was arraigned and trial was had.
Issue:
Whether or not the accused is exempted from the criminal liability on
the ground of the doctors findings that he is suffering from dementia
praecox?
Held:
Insanity as a defense in a confession and avoidance must be proved
beyond reasonable doubt when the commission of the crime is established.
When a defendant in a criminal case interposes the defense of mental
incapacity, the burden of establishing that fact rests upon him. In this case,
the defense interposed that the defendant was insane at the time he killed
the deceased. Prior to the commission of the offense, he was confined in the
insane department of the San Lazaro Hospital suffering from a disease
diagnosed as dementia praecox. The circumstance tends to show that the
recurrence of the ailment at the time of the occurrence of the crime is not
entirely lacking of any rational or scientific foundation. 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. It
is similar to those of manic depressive psychosis where the mind appears

deteriorated because when a person becomes affected by this kind of

disease, during the time of excitement, he has no control whatever he acts.
The accused was held by the court to be exempted from criminal liability.