Case Digest (A.M. No. 439-MJ) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippine Islands v. Donato Bascos (G.R. No. 19605, December 19, 1922), the Court of First Instance of Pangasinan prosecuted Donato Bascos for the murder of Victoriano Romero. Bascos pleaded not guilty at arraignment. Evidence showed that Romero was killed while asleep, and the defense asserted that Bascos was insane at the time of the killing. The trial court found the accused guilty of homicide, sentenced him to reclusion temporal of seventeen years, four months, and one day, imposed accessory penalties, ordered indemnification of P1,000 to Romero’s heirs, and awarded costs. However, pursuant to article 100 of the Penal Code, the court suspended execution of the sentence and directed that Bascos be confined in a mental hospital until his mental state could be determined. Bascos appealed, assigning as error the trial court’s reliance on article 100 instead of article 8 of the Penal Code, which exempts an imbecile or lunatic who acts during an interval of i Case Digest (A.M. No. 439-MJ) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and charge
- The People of the Philippine Islands filed an information in the Court of First Instance of Pangasinan charging Donato Bascos with the murder of Victoriano Romero.
- On arraignment, Bascos pleaded not guilty.
- Trial proceedings
- Prosecution evidence established that Bascos killed Romero while the latter was sleeping.
- Defense interposed the plea of insanity.
- The trial court found Bascos guilty of homicide and sentenced him to seventeen years, four months, and one day of reclusion temporal, ordered indemnity of ₱1,000 to Romero’s heirs, costs, and suspended the execution of sentence under article 100 of the Penal Code, committing the accused to a hospital for the insane until recovery.
- Appeal and assigned errors
- Appellant assigned error to the application of article 100 rather than article 8 of the Penal Code.
- The Attorney-General concurred, contending that article 8 should govern.
Issues:
- Which provision of the Penal Code applies to Bascos’s plea of insanity—article 8 (exemption of lunatics) or article 100 (post-sentence insanity)?
- What is the proper allocation of the burden of proof when insanity is pleaded in a criminal case?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)