CD - 5. People Vs Bonoan

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Facts:

Celestino Bonoan is charged with the crime of murder for stabbing Carlos Guison with a knife, which
caused his death three days afterwards. An arraignment was then called, but the defense objected on
the ground that the defendant was mentally deranged and was at the time confined at the Psychopatic
Hospital. After several months of summons for doctors, production of the defendant’s complete record
of mental condition from the hospital and defendant’s admission to the hospital for personal
observation, assistant alienist Dr. Jose Fernandez finally reported to the court that Bonoan may be
discharged for being a “recovered case”. After trial, the lower court found Bonoan guilty and sentenced
him to life imprisonment.

The defense now appeals, claiming the lower court made errors in finding Bonoan suffered dementia
only occasionally and intermittently, did not show any kind of abnormality, that the defense did not
establish the defendant’s insanity and finding accused guilty.

Procedural History:

After trial, the lower court found the defendant guilty of the offense charged in the information above-
quoted and sentenced him to life imprisonment, to indemnify the heirs of the deceased in the sum of
P1,000, and to pay the costs.

 
Judgment:

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. This ruling was based on the following evidence:

1. Uncontradicted evidence that accused was confined in the insane department of San Lazaro
Hospital and diagnosed with dementia praecox long before the commission of the offense and
recurrence of ailments were not entirely lacking of scientific foundation
2. Persons with dementia praecox are disqualified from legal responsibility because they have no
control of their acts; dementia praecox symptoms similar to manic depression psychosis
3. Accused had an insomnia attack, a symptom leading to dementia praecox, four days prior to
act according to Dr. Francisco
4. Accused was sent the Psychopatic hospital on the same day of crime and arrest, indicating
the police’s doubt of his mental normalcy
5. Defendant suffered from manic depressive psychosis according to Dr. Joson

Application of Legal Medicine Concept in the Case:

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 (People vs. Tripler, supra) to
established 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 his acts conform to
the practice of people of sound mind. To prove insanity, therefore, cicumstantial evidence, if clear and
convincing, suffice.

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