Case Digest (G.R. No. 19605)
Facts:
The People of the Philippine Islands v. Donato Bascos, G.R. No. 19605. December 19, 1922, the Supreme Court En Banc, Malcolm, J., writing for the Court. The plaintiff-appellee was The People of the Philippine Islands; the defendant-appellant was Donato Bascos.
An information was filed in the Court of First Instance of Pangasinan charging Bascos with the murder of Victoriano Romero. On arraignment Bascos pleaded not guilty. At trial the prosecution established that Bascos killed Romero while Romero was sleeping. The defense pleaded insanity. After the trial the presiding judge found Bascos guilty of homicide and sentenced him to seventeen years, four months, and one day of reclusion temporal with accessory penalties and indemnity of P1,000 to the heirs of Romero; however, the trial court suspended execution pursuant to Article 100 of the Penal Code and ordered Bascos placed in a hospital for the insane until his mental condition should be determined.
Bascos appealed, assigning as error the trial court’s application of Article 100 rather than Article 8, paragraph 1 of the Penal Code. The Attorney-General agreed with appellant that Article 8 was the applicable provision. The case reached the Supreme Court by appeal. The Court examined the evidence, including testimony of the accused’s wife and cousin that he had been “more or less continuously out of his mind for many years,” and the report and testimony of Dr. Gonzalo Montemayor, assistant district health officer, who, after court-ordered examination and investigation, declared the accused to be a “violent maniac” and ex...(Pro-only)
Issues:
- Who bears the burden of proof on the issue of insanity in a criminal prosecution — the prosecution to prove sanity, or the defendant to prove insanity?
- Did the trial court err in applying Article 100 of the Penal Code (insanity after sentence) rather than Article 8, paragraph 1 (exemption for imbeciles and lunatics)?
- Was the evidence sufficient to show that Bascos was insane at the time of the killing and therefore exempt from criminal...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)