Crim Law (#25)

The People of the Island of the Philippines

VS.
PotencianoTaneo
G.R. No. L-37673
March 31, 1933

Nature of Actions: An appeal from the judgment of Regional Trial Court, Branch 5 of Cebu City.

Facts:
PotencianoTaneo lives in the house of his wifes parents in a barrio of Ormoc, Leyte. On January
16, 1932, a fiesta was being celebrated in the said barrio and visitors were entertained in the house.
Among them were Fred Tanner and Luis Malinao. Earlier in the afternoon he fell ill and slept early. While
dreaming, he stood up with a bolo on his hand, and upon meeting his seven-month-pregnant wife who
tried to stop him, he wounded her which caused her death 5 days later because of the inflicted wound.
He also wounded his visitors, Tanner and Malinao, even his wifes father, and lastly, himself.

The trial court found Potenciano guilty of parricide and was sentenced to reclusion perpetua.

It appears from the evidence that the day before the incident, Potenciano had a quarrel over a
glass of tuba with Enrique Collantes and Valentin Abedilla, who invited him to come down to fight, and
when he was about to go down, he was stopped by his wife and his mother. And on the day of the
incident, it was noted that he was sad and weak, and had a severe stomach ache which was the reason
why he slept early. It was then when he fell asleep, Potenciano states that he dreamt that Collantes was
stabbing him with a bolo and Abedilla was holding his feet, by reason of which he got up and defended
himself by getting the bolo and leaving the room.

The evidence also shows that Potenciano not only did not have any trouble with his wife, but
that he loved her dearly. Neither did he have any dispute with Tanner and Malinao, or have any motive
for assaulting them.

Issue: Is PotencianoTaneo criminally liable of the felony he committed?

Ruling: In view of all these considerations, and reserving the judgment appealed from, the court finds
that the defendant is not criminally liable for the offense with which he is charged, and it is ordered that
he be confined in the Government Insane Asylum, whence he shall not be released until the director
thereof finds that his liberty would no longer constitute a menace, with costs de oficio. So ordered.

Ratio Decidendi:

The defendant acted in a dream which shows his lack of intent and motive, and his actions are
not voluntary, therefore his acts do not constitute a criminal liability and must not be given such penalty
and punishment.

Dr. Serafica, an expert witness of the case, stated that the defendant acted while in a dream,
under the influence of a hallucination and not in his right mind.

Although there was a lack of motive and intent, it does not necessarily mean that he is not
criminally liable, but that they are not known to us. In this case, the court found that there was
insufficient evidence of intent to do such crime (Potenciano not only did not have any trouble with his
wife, but that he loved her dearly) but also motives to do the act voluntarily. Hence, it is justifiable that
the judgment he appealed from should be reversed, and that it is also justifiable that he be detained in
the Govt Insane Asylum, until he is well enough to be released.