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ScribblesofaLunaticMind:Peoplevs.Taneo[58Phil.255(1933)]
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I'M A SCHIZOPHRENIC! I'M HAPPY! I'M PROUD TO BE ONE!
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Peoplevs.Taneo[58Phil.255(1933)]
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Postundercasedigests,CriminalLawatWednesday,February29,2012PostedbySchizophrenicMind
Facts:PotencianoTaneoandhiswifelivedinhisparent'shousein
Dolores, Ormoc. On January 16, 1932, a fiesta was being
celebrated in the said barrio and guests were entertained in the
house,amongthemwereFredTannerandLuisMalinao.Earlythat
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
attackedFredandLuisandtriedtoattackhisfather,afterwhich,he
woundedhimself.Potenciano'swife,whowas7monthspregnantat
thattime,diedfivedayslaterasaresultofthewound.
The trial court found Potenciano guilty of parricide and was
sentencedtoreclusionperpetua.
Itappearsfromtheevidencethatthedaybeforethecommissionof
the crime, the defendant had a quarrel over a glass of "tuba" with
Collantes and Abadilla, who invited him to come down and fight.
Whenhewasabouttogodown,hewasstoppedbyhiswifeandhis
mother.Onthedayofthecommissionofthecrime,itwasnotedthat
thedefendantwassadandweak,hadaseverestomachachethat's
whyhewenttobedintheearlyafternoon.Thedefendantstatedthat
when he fell asleep, he dreamed that Collantes was trying to stab
himwithabolowhileAbadilaheldhisfeet.That'swhyhegotupand
itseemedtohimthathisenemieswereinvitinghimtocomedown
hearmedhimselfwithaboloandlefttheroom.Atthedoor,hemet
hiswifewhoseemedtosaytohimthatshewaswounded.Then,he
fanciedseeinghiswifereallywoundedandindesperationwounded
himself.Ashisenemiesseemedtomultiplyaroundhim,heattacked
everybodythatcamehisway.
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Issue:Whetherornotdefendantactedwhileinadream.
villaramadoctrines(103)
Held: Yes. The defendant acted while in a dream & his acts,
therefore, werent voluntary in the sense of entailing criminal
liability.
The apparent lack of motive for committing a criminal act does not
necessarily mean that there are none, but that simply they are not
knowntous.Althoughanextrememoralperversionmayleadaman
to commit a crime without a real motive but just for the sake of
committing it. In the case at hand, the court found not only lack of
motivesforthedefendanttovoluntarilycommittheactscomplained
of (read: he loved his wife dearly, he tried to attack his father in
whose house the lived and the guests whom he invited), but also
motivesfornotcommittingtheacts.
603,618
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