Martin, Christian Paolo G.

1H

THE PEOPLE OF THE PHILIPPINES

vs.
CELESTINO BONOAN Y CRUZ

G.R. No. L-45130 ; February 17, 1937

LAUREL, J.:

Facts:

On January 5, 1935, the prosecuting attorney of the City of Manila filed an information
charging Celestino Bonoan, the defendant. That on or about the 12th day of December, 1934, in
the City of Manila, Philippine Islands, the said accused, with evident premeditation and
treachery, did then and there willfully, unlawfully and feloniously, without any justifiable motive
and with the decided purpose to kill one Carlos Guison, attack, assault and stab the said Carlos
Guison on the different parts of his body with a knife.

On January 16, 1935, the case was called for the arraignment of the accused. The defense
counsel objected to the arraignment on the ground that the defendant was mentally deranged
(insane) and was at the time confined in the Psychopatic Hospital. The court thereupon issued an
order requiring the Director of the Hospital to render a report on the mental condition of the
accused. Dr. Jose Fernandez (assistant alienist of the Psychopatic Hospital) appeared before the
court and ratified his report, Exhibit 5, stating that the accused was not in a condition to defend
himself. In view thereof, the case was suspended indefinitely. A year after (January 21, 1936),
Dr. Fernandez reported to the court that the defendant could be discharged from the hospital and
appears for trial, as he was "considered a recovered case." Summoned by the court, Dr.
Fernandez appeared and testified that the accused "had recovered from the disease." and that the
accused has had dementia only occasionally and intermittently and has not had it immediately
prior to the commission of the defense. The trial court found the accused guilty for the crime of
murder. The defense appealed that the court erred in rendering its decision and seek its reversal.

Issue:

Whether or not the accused can be considered as an Insane under Article 12 of the Revised Penal
Code; hence, cannot be made criminally liable.

Held:

Yes, The Court finds the accused demented at the time he perpetrated the crime, which
consequently exempts him from criminal liability, and orders for his confinement in San Lazaro
Hospital or other hospital for the insane.
Basis:

INSANITY IS A DEFENSE (Article 12 Par. 1) The person raising the defense of Insanity has
the Burden of Proof of proving the existence of the mental incapacity at the time of the
commission of the crime; to ascertain a persons mental condition, sufficient/circumstantial
evidence of the condition of his mind both before and after the commission of the crime (NOT
Direct testimony or Specific acts of derangement).

INSUFFICIENT EVIDENCE OF THE PROSECUTION To prove motive and premeditation

and mental normalcy of the accused at the time of the commission the prosecution relied to the
testimony of the policemen who arrested the defendant; that such testimony is not necessarily
proof of the sanity of the defendant during the commission of the crime.

SAME: CRIMINAL EVIDENCE In Dementia Praecox (the mental condition of the

accused) the crime is usually preceded by much complaining and planning; that homicidal
attacks are common, because of delusions that they are being interfered with sexually or their
property is being taken.