PEOPLE v. BONOAN [64 Phil.

87 (1937)]
Nature: Appeal from a judgment of the CFI of Manila
Facts:
12 Dec. 1934 - Celestino Bonoan met Carlos Guison on Avenida Rizal near
a barbershop close to Tom's Dixie Kitchen. Francisco Beech, who was at the time
in the barbershop, heard Bonoan say in Tagalog, "I will kill you." Beech turned
around & saw Bonoan withdrawing his right hand, w/c held a knife, from the
side of Guison who said, "I will pay you," but Bonoan simply replied saying that
he would kill him & then stabbed Guison 3 times on the left side. The incident
was witnessed by policeman Damaso Arnoco. Bonoan was arrested on the day
itself. Bonoan admitted to stabbing Guison. Guison was taken to PGH where he
died 2 days later.
5 January 1935 - Prosecuting attorney of Manila filed an information
charging Celestino Bonoan with the crime of murder.
16 January 1935 - Bonoan's 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. The court issued and order requiring the
Director of the hospital to report on Bonoan's mental condition. A report was
rendered by Dr. Toribio Joson.
23 March 1935 - the case was called for arraignment again, the defense
objected and again the court filed another order requiring the doctor who
examined Bonoan to appear in court to report on Bonoan's mental condition.
26 March 1935 - Dr. Toribio appeared before the court for the inquiry.
The court issued another order asking to summon other doctors from the hospital
and to put Bonoan under another doctor, Dr. Jose Fernandez, for closer
observation. Dr. Fernandez filed his report on 11 June 1935.
28 June 1935 the case was called again, Dr Fernandez showed up in court
and reported that Bonoan was still not in a condition to defend himself.
21 January 1936 - Dr. Fernandez reported to the court that
Bonoan could be discharged from the hospital and appear for trial as he was
"considered a recovered case."
27 February 1936 - Bonoan was arraigned and pleaded "not guilty" and
the trial was held. To prove motive and mental normalcy of Bonoan the
prosecution called on Damaso Arnoco who testified that the reason for Bonoan's
attack was that Guison owed him P55 and would not pay him back. Bonoan had
bought the knife with which he stabbed Guison for 50 centavos and had been
waiting 2 days to kill him. He acquired this information when he arrested and
questioned Bonoan. Bonoan was charged with the murder of Carlos Guison, and
sentenced him to life imprisonment and to pay P1K to indemnify the heirs of
Guison.
The defendant appealed the case and his counsel cited that the lower court
had erred in finding that Bonoan had dementia intermittently and not
immediately prior to the commission of the offense, in finding that the accused
did not show any abnormality either in behavior, action, language, appearance,
or action that he was mentally deranged, in finding that the burden of proof lay
in the defendant to prove that he was mentally deranged at the time of the crime,
and in not acquitting Bonoan.
Issue: WON Bonoan was insane at the time of the commission of the crime.
Held: Yes. There are 3 different theories used
(1) Insanity as a defense in a confession and avoidance and as such must be
proved beyond reasonable doubt. Proof of insanity at the time of committing the
criminal act should be clear and satisfactory in order to acquit the accused on the
ground of insanity. (Philippines uses this)
(2) That an affirmative verdict of insanity is to be governed by preponderance
of evidence, and in this view, insanity is not to be established beyond a reasonable
doubt.
(3) Prosecution must prove sanity beyond a reasonable doubt.
When a defendant in a criminal case interposes the defense of mental incapacity,
the burden of establishing the fact rests upon the defendant. To prove insanity the
evidence must be clear and convincing. The courts need to distinguish insanity in
law from passion or eccentricity, mental weakness or mere depression resulting
from physical ailment. In the separate reports given by Dr. Toribio Joson and Dr.
Fernandez they both diagnosed Bonoan to be unstable, stating that "he will
always have troubles and difficulties with this world of realities." Bonoan was
diagnosed with dementia praecox which is a mental disease that disqualifies a
person from legal responsibility for his actions. In these people homicidal attacks
are common because of the delusions that they are being interfered with or that
their property is being taken. The court was of the opinion that Bonoan was
demented at the time he perpetrated the serious offense charge with and that
consequently he is exempt from criminal liability.
Judgment: Judgment of the lower court REVERSED. Defendant appellant
ACQUITTED but to be kept in confinement in the San Lazaro Hospital or any
other hospital for the insane.

Imperial, dissenting: "The dissenting opinions, in establishing the conclusion that

the accused was then in the possession of his mental faculties or, at least, at a
lucid interval, are based on the fact admitted by the parties and supported by
expert testimony, that the accused before the commission of a crime, had been
cured of dementia praecox and later of manic depressive psychosis." The
inference of the majority that the accused was insane is not sufficiently supported
by evidence. No attention was given to the decision of the judge who originally
tried the case, which should have been done because he was able to observe
Bonoan, the witnesses, the evidence and the testimonies. This court generally
gives importance to the conclusions drawn by the judge who tried the case in
first instance unless there is a clear contradiction in the evidence and the
decision, which is not the case here.
Diaz, dissenting: The appellant committed the crime when he was sane or at least
during a lucid interval. He had motive to kill Guison [55php], as clearly stated by
the arresting police officer. The law presumes that everyone is sane, and insanity
is an exception, to be established by clear proof and it is not usually permanent.
There is no evidence or record that can prove that Bonoan was insane at the time
he committed the crime, or that he was continuing to suffer from insanity from
the date of the commission of the crime. Where it is shown that the defendant
experiences lucid intervals, the crime is assumed to have been committed during
one of them, unless proven otherwise.
Concepcion, dissenting: There is no evidence or record to prove that Bonoan was
insane at the time he committed the crime, and there were no records to show
that he had suffered a relapse of the condition he had sought treatment for at the
San Lazaro hospital years before the crime was committed. Bonoan had been sane
for 9 years [or at least "socially adjustable"]. The attack of insomnia before the
event is not clear proof that he was insane or suffering a bout with insanity at the
time of the crime, it merely presents a possibility, and the innocence to the
accused cannot be based on a mere possibility. The accused when questioned by
the police immediately after the crime did not exhibit insane behavior. It cannot
be said that Bonoan stabbed Guison because of a hallucination because Guison
actually owed him money and this was confirmed by the fact of his saying "I am
going to pay you" before he was stabbed. This shows the motive for aggression
[vengeance]