Professional Documents
Culture Documents
People vs Bonoan
Laurel, J.:
On December 12, 1934, accused, Celestino Bonoan allegedly
stabbed Carlos Guison on the different parts of his body with a knife,
thereby inflicting upon him stab wounds n the liver, posterior and lateral
lumbar region, and left elbow, which caused Guisons death three days
afterwards. Bonoan met Carlos Guison on Avenida Rizal near a
barbershop close to Toms Dixie Kitchen. Beech, who was one of the
witnesses, allegedly heard the accused say in Tagalog, I will kill you,
before stabbing the victim thrice on the left side. Bonoan stabbed the
latter when he refused topay the P50 debt he owed the former, and this
was evidenced by the testimony of a police officer who witnessed the
event. The accused had also been confined in the insane deparment of the
San Lasaro Hospital (suffering from dementia praecox) in 1922 and in
1926.
The defense objected to the arraignment of the said case on the
grounds that the accused was mentally deranged and at that time,
confined in the Psychopatic Hospital. Doctors of the hospital were
summoned by the court to be questioned with regard to the mental
condition of the defendant. Dr. Fernandez, one of the hospitals doctors,
appeared before the court and testified that the accused was not in a
condition to defend himself, after which, the case was suspended
indefinitely. Soon thereafter, the same doctor appeared before the court
and testified that the accuesed had recovered from the disease. Case
continued, accused pleaded not guilty
The lower court found the defendant guilty of murder and was
sentenced with life imprisonment, and to indemnify the heirs of the
deceased in the sum of P1000 and to pay the costs. Accused appealed to
this Court thenafter.
THE PEOPLE
HONORATO
OF
THE
PHILIPPINES, plaintiff-appellee,
AMBAL, accused-appellant.
vs.
Aquino, J.:
In the morning of 20 January 1977, the barangay captain found Felicula
(Feling), 48 and married to Honorato Ambal, under some flowering plants near
the couples house in Barrio Balbagon, Mambajao, Camiguin. She was mortally
wounded, having 7 incised wounds in different parts of her body. She asked for
drinking water and medical assistance. She was placed in an improvised
hammock and brought to the hospital. She died 40 minutes later. Honorato
admitted to killing his wife. After leaving their child to a neighbor, he went to
the house of the barangay captain and told the latters wife that he had killed
Feling. Then, he took a pedicab, went to the municipal hall and surrendered to a
policeman, again confessing that he killed his wife. The policeman confiscated
his long bolo, the tip of which was broken. His shirt was torn, he was
bespattered with blood, and he appeared to be weak. The two had been married
for 15 years, and quarreled and bickered a lot. Feling sometimes didnt stay in
the home and spent the night in the poblacion of Mambajao. They had 8
children. The immediate provocation for the assault was a fight, because Feling
had not bought medicine for Honorato, who then had influenza. She told him
that he was better off dead (Mas maayo ka pang mamatay.) so he attacked her.
He was charged with parricide on 27 January 1977 in the municipal court, and
was elevated to the CFI on 4 March 1977. He pleaded not guilty. His defense
was insanity. Two doctors were brought to the stand:
o Dr. Maximino Balbas, Jr., the municipal health officer, found him to be have
suffered frompsychosis due to short frustration tolerance during the
commission of the crime but was normal before and after the commission. He
also said that Ambal was a passive-aggressive, emotionally unstable,
explosive or inadequate personality.
o Dr. Cresogono Llacuna, who undertook a 2-month observation of mental cases
and treated around 100 cases of mental disorders, said that Ambal suffered from
a minor psycho-neurosis, a disturbance of the functional nervous system which
is NOT INSANITY. He was normal but nervous, and HAD NO MENTAL
DISORDER.
Abad Santos, J, concurring: Adds the observation that Feling was a shrew,
and that the worst thing that can happen to a person is to have an
unbearable spouse.She was also neglectful and even had the gall to tell
him that he was better off dead. This, plus the mental disorder, should entitle
him to two additional mitigating circumstances: obfuscation and illness. But
under the circumstances, appellant is deserving of executive clemency, and
so he recommends it.
No. For insanity to relieve the person of criminal liability, it is necessary that
there be a complete deprivation of intelligence in committing the act, that he
acts without the least discernment and that there be complete absence or
deprivation of the freedom of the will. Under Philippine jurisdiction, there's
no definite test or criterion for insanity. However, the definition of insanity
under Sec 1039* of the Revised Administrative Code can be applied. In
essence, it states that insanity is evinced by a deranged and perverted
condition of the mental faculties, which is manifested in language or
conduct. An insane person has no full and clear understanding of the nature
and consequence of his act. Evidence of insanity must refer to the mental
condition at the very time of doing the act. However, it is also permissible to
receive evidence of his mental condition for a reasonable period before and
after the time of the act in question. The vagaries of the mind can only be
known by outward acts. It is not usual for an insane person to confront a
specified person who may have wronged him. But in the case at hand, the
accused was able to Mrs. Sigua. From this, it can be inferred that the accused
was aware of his acts. This also established that the accused has lucid
intervals. Moreover, Dr. Echavez testified to the effect that the appellant
could have been aware of the nature of his act at the time he committed it
when he shouted (during laboratory examination) that he killed Mrs. Sigua.
This statement makes it highly doubtful that the accused was insane when he
committed the act. The fact that the accused was carrying an envelope where
he hid the fatal weapon, that he ran away from the scene of the incident after
he stabbed the victim several times, that he fled to Manila to evade arrest,
indicate that he was conscious and knew the consequences of his acts in
stabbing the victim. (This was taken from the trial court's decision).
Whether or not the appellant can use the defense of insanity in killing of Jerry
Tejamo
Per Curiam:
RTC found Randy Belonio y Landas guilty of the murder of Ramy
Tamayo and sentenced him to death. On January 6, 2000, Jennifer
Carampatanas grandmother was buried and there was a wake in their house
in the evening. Her first cousin, the late Ramy Tamayo, arrived in their house
with his wife around 10:00 P.M. Jennifer invited Ramy to talk outside of
their house. Before they could sit on a nearby bench, Ramy decided to buy
cigarettes from a store only a few meters away. The store was furnished with
a small opening for the store-keeper to attend to the customers and Ramy
was occupying that space in front of the opening to pay when the accused
Randy Belonio arrived. Randy tried to force his way in front of the opening
and as a consequence, he bumped on Ramy. Jennifer saw that Randy gave
Ramy a long and hard look. Jennifer and Ramy sat and talked on the bench.
The accused came over and sat on the other end of the bench. Then the
accused asked Ramy for the latters cigarette lighter and conversed with him.
The accused left but after a few minutes he returned, Jennifer, who was
facing the direction of the approaching accused, saw him and noticed that he
was wearing long sleeves. Ramy Tamayo could not see the accused as he
was facing sideways to Jennifer. Without saying a word and without
warning, the accused delivered a stabbing blow with a dagger which was
concealed in his hand. Ramy was hit on the right chest, Jennifer stood up and
ran towards her house shouting for help. There at the gate of the fence of her
house, she heard another thudding sound of a stabbing blow. When Jennifer
entered her house, she announced that Ramy was stabbed. The accused ran
away towards the back of the barangay hall but was later arrested from one
(1) of the houses near the barangay hall where he took refuge.
Randy Belonio raised the defense of insanity, an exempting circumstance,
and relied on the expert assessment of his witness, Dr. Antonio Gauzon, who
certified thus: This is an individual who is suffering from (Schizophrenia),
Chronic Undifferentiated and probably triggered by (s)ubstance abuse of
Shabu and Marijuana. RTC found appellant guilty of Murder and that he
had full control of his mental faculties.
No. Whoever invokes insanity as a defense has the burden of proving its
existence. In the case at bar, the defense utterly failed to discharge its burden
of proving that appellant was insane. The evidence adduced by the defense is
sorely insufficient to establish his claim that he was insane at the time he
killed Tamayo. In the eyes of the law, insanity exists when there is a
complete deprivation of intelligence in committing the act. Proof of the
existence of some abnormality of the mental faculties will not exclude
imputability, if it can be shown that the offender was not completely
deprived of freedom and intelligence. Belonio, after giving the victim a hard
and resentful look, sat near the latter, lighted his cigarette and conversed with
him. Afterwards, he left and came back armed with a dagger with which he
stabbed Tamayo. Immediately thereafter, he escaped and went into hiding.
These acts tend to establish that Belonio was well aware of what he had just
committed, and was capable of distinguishing right from wrong. Otherwise,
he would not have attempted to escape and go into hiding. The only other
evidence of insanity that appellant pointed to is the medical certificate
prepared by Dr. Antonio Gauzon stating that Belonio was suffering from
schizophrenia. Dr. Gauzon testified that based on his interview with Belonio
on October 25, 2000 (around nine months after the stabbing incident) the
latter was suffering from schizophrenia. However, the evidence of insanity
after the fact of commission of the offense may be accorded weight only if
there is also proof of alleged abnormal behavior immediately before or
simultaneous to the commission of the crime. Dr. Guazons report was silent
as regards the incidents occurring prior to or during the circumstance for
which Belonio stands trial. The story narrated by the doctor was a mere life
and family history of Belonio. There was no showing that he was actually
suffering from schizophrenia during his juvenile years. To demonstrate that
he had been suffering from this condition, the doctor pointed to the fact that
he has already killed three (3) persons, including the present incident.
However, such conclusion is non sequitur and, at best, a circuitous argument.
Further, the veracity of these findings is belied by the fact that the accused
did not raise this defense during his prosecutions for the other killings. No
other circumstances evincing its existence were presented during trial.
Potenciano Taneo and his wife lived in his parent's house in Dolores,
Ormoc. On January 16, 1932, a fiesta was being celebrated in the said barrio
and guests were entertained in the house, among them were Fred Tanner and
Luis Malinao. Early that afternoon, Potenciano went to sleep and while
sleeping, he suddenly got up, left the room bolo in hand and, upon meeting
his wife who tried to stop him, wounded her in the abdomen. He also
attacked Fred and Luis and tried to attack his father, after which, he wounded
himself. Potenciano's wife, who was 7 months pregnant at that time, died five
days later as a result of the wound. The trial court found Potenciano guilty of
parricide and was sentenced to reclusion perpetua. It appears from the
evidence that the day before the commission of the crime, the defendant had
a quarrel over a glass of "tuba" with Collantes and Abadilla, who invited him
to come down and fight. When he was about to go down, he was stopped by
his wife and his mother. On the day of the commission of the crime, it was
noted that the defendant was sad and weak, had a severe stomachache that's
why he went to bed in the early afternoon. The defendant stated that when he
fell asleep, he dreamed that Collantes was trying to stab him with a bolo
while Abadila held his feet. That's why he got up and it seemed to him that
his enemies were inviting him to come down; he armed himself with a bolo
and left the room. At the door, he met his wife who seemed to say to him that
she was wounded. Then, he fancied seeing his wife really wounded and in
desperation wounded himself. As his enemies seemed to multiply around
him, he attacked everybody that came his way.
Issue, ruling, and discussion
Whether or not defendant acted while in a dream
Yes. The defendant acted while in a dream & his acts, therefore, werent
voluntary in the sense of entailing criminal liability. The apparent lack of
plaintiff-appellee,
Yes. The accused acted with discernment. Accused mistakes the discernment
for premeditation, or at least for lack of intention, as a mitigating
circumstance. However, the DISCERNMENT that constitutes an exception
to the exemption from criminal liability of a minor under 15 years but over
nine, who commits an act prohibited by law, is his MENTAL CAPACITY to
understand the difference between right and wrong, and such capacity may
be known and should be determined by taking into consideration all the facts
and circumstances afforded by the records in each case, the very appearance,
the very attitude, the very comportment and behavior of said minor, not only
before and during the commission of the act, but also after and even during
the trial.
doing so, had wounded Omamdam, he would be liable for his act, since
whoever willfully commits a felony or a misdemeanor incurs criminal
liability, although the wrongful act done is different from that which he
intended. This is not the case here. Bindoy did not try to wound Pacas. He
was only trying to defend his possession of the bolo, which Pacas was trying
to wrench away from him. His conduct was perfectly lawful
No. The idea that Tanedo intended to kill Sanchez is negated by the fact that
the chicken and the man were shot at the same time, there having only one
shot fired. Also, according to: a. Article 1 of the Penal Code: Crimes or
misdemeanors are voluntary acts and omissions punished by law b. Article
8: He who while performing a legal act with due care, causes some injury by
mere accident without liability or intention of causing it. C. Section 57 of