People v. Taneo (CASE DIGEST)

People v.
Taneo (CASE DIGEST)
G.R. No. L-37673
March 31, 1933
FACTS: Potenciano Taneo is living with his wife in his parent’s house. On 1932, during a
fiesta, Taneo entertained Fred and Luis as guests in his house. Early that afternoon, Taneo,
went to sleep and while sleeping, he suddenly got up, and with a bolo in hand left the room.
When his wife who tried to stop him, he wounded her in the abdomen. Taneo also attacked
his guests and tried to attack his father. Taneo also wounded himself. His wife who was
then seven months pregnant, died five days later as a result of her wound, and also the
fetus which was asphyxiated in her womb.
Taneo was charged with parricide and sentenced with reclusion perpetua. In which the
defendant appealed.
According to the evidence, on the day before the commission of the crime the Taneo had a
quarrel over a glass of “tuba” with some enemies. On the day of the crime, Taneo was sad
and weak, and had severe stomachache. Taneo states that when he fell asleep, he dreamed
that his enemies were trying to stab him by reason of which he got up, armed himself with a
bolo and left the room. At the door, he met his wife and seeing her wounded, he also
wounded himself. Taneo claims seeing his enemies seemed to multiply around him in which
he attacked everybody that came his way.
The evidence also showed that Taneo dearly loved his wife and did not have any trouble
with his guests in which he injured.
ISSUE: Whether or not Taneo is criminally liable.
RULING: The Court found that the defendant is not criminally liable ordered him to be
confined in the Government insane asylum.
Principle:
The Court concluded that the defendant acted while in a dream. His acts were not voluntary
in the sense of entailing criminal liability. There is a lack of motive for the defendant to
voluntarily commit the acts and he has motives for not committing said acts.
The Court took the special circumstances in which he dearly loved his own wife and taking
into consideration that he tried to attack also his father and his guests.
Doctor Serafica, an expert witness in this case stated that considering the circumstances of
the case, the defendant acted while in a dream, under the influence of a hallucination and
not in his right mind.
PEOPLE V BONOAN
Facts:
Celestino Bonoan is charged with the crime of murder for stabbing Carlos Guison with a
knife, which caused his death two days after.
It was said that Bonoan waited for the victim, Guison near a barbershop. A witness heard
Bonoan say “I will kill you” and saw him stab the victim three times. A policeman also
witnessed the assault and arrested Bonoan. When he was questioned, he stated that Guison
owed him 55 pesos.
An arraignment was called, but the defense objected stating that the defendant was
mentally deranged and confined at the Psychopathic Hospital. After several months of
summons for doctors, experts, and reports regarding Bonoan’s mental condition, Dr.
Fernandez, an alienist reported that Bonoan was not in the condition to defend himself.
A year after, Dr. Fernandez reported that Bonoan recovered and can report in trial. In the
arraignment, he pleaded not guilty, however, the lower court found him guilty and
sentenced him to life imprisonment.
The defense appealed that Bonoan was mentally deranged at the time of the commission of
the crime.
Testimonies from experts and reports from hospitals showed that Bonoan was suffering of
dementia praecox. There was also a testimony that 4 days before the crime was committed,
Bonoan had insomnia attacks which is a symptom that leads to dementia and that after his
arrest, Bonoan was sent to a psychopathic hospital.
Issue: Whether or not Bonoan was insane at the time of the commission of the crime and is
therefore not criminally liable.
Ruling: The Supreme court reversed the decision of the lower court. The defendant was
acquitted and shall be kept in confinement in the psychopathic hospital until the court shall
otherwise order.
Principle: 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 evidence
that Bonoan was diagnosed with dementia praecox and recurrence of ailments were is not
lacking of scientific foundation. Persons with dementia praecox are disqualified from legal
responsibility because they have no control of their acts.
Bonoan had an insomnia attack, a symptom leading to dementia praecox, four days before
he committed the crime. Also, he was sent the Psychopatic hospital on the same day of
crime and arrest, indicating the police’s doubt of his mental normalcy. And that according to
experts and submitted reports, Bonoan is suffering from manic depressive psychosis at the
time of the commission of the act.

Dissenting: Justices Imperial, Diaz and Concepcion dissented with the following reasons:
That the accused committed the crime when he was sane, or at least, during a lucid
interval. The justices also claimed that the legal presumption should always held that the
accused in his sanity when committing the crime. According to them, there was no positive
evidence of the accused mental state was established and that he was cured of dementia
long before he committed the crime. And that there is a motive of aggression on part of
accused is real and positive fact which is the failure to pay the borrowed money.

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People v. Taneo (CASE DIGEST)

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People v.

Taneo (CASE DIGEST)

G.R. No. L-37673

March 31, 1933

ISSUE: Whether or not Taneo is criminally liable.

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