PEOPLE V BONOAN

11 Feb

L-45130 | February 17, 1937 | J. Laurel

Imbecility

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 defendants complete record of mental condition from the
hospital and defendants 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
defendants insanity and finding accused guilty.

Issue:

W/N the lower court erred in finding the accused guilty

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.
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 polices
doubt of his mental normalcy
5. Defendant suffered from manic depressive psychosis according to Dr. Joson

Dissenting (Justices Imperial, Diaz and Concepcion):

o The dissenting opinions pose that the accused committed the crime when he was sane, or at
least, during a lucid interval.
o The legal presumption is always in favor of sanity; no positive evidence of accused mental state
was established
o Based on expert testimonies, accused was cured of dementia praecox and later manic
depressive psychosis
o Based on observance of arresting officer Damaso Arnoco, corrobating statement of Benjamin
Cruz, and other witnesses, accused appear sane at the time immediately after commission
o There is a motive of aggression on part of accused is real and positive fact: deceaseds failure to
pay borrowed money