Case Digest (G.R. No. 45130)
Facts:
This case, People of the Philippines vs. Celestino Bonoan y Cruz, G.R. No. 45130, was decided by the Supreme Court on February 17, 1937. The accused, Celestino Bonoan, was charged with murder for stabbing one Carlos Guison in Manila on or about December 12, 1934. The stabbing inflicted multiple wounds, including a penetrating injury to the liver, which caused Guison's death three days later. The prosecution alleged that Bonoan committed the crime with premeditation and treachery. At trial, the defense raised insanity as a ground for exclusion of criminal liability, contending that Bonoan was mentally deranged due to a history of mental illness including dementia praecox (schizophrenia) and manic depressive psychosis. Prior to the crime, Bonoan had undergone confinement in mental hospitals in 1922 and 1926 and, after the crime, was confined again in the Insular Psychopathic Hospital where he was diagnosed with manic depressive psychosis. The trial court found him guilty and
Case Digest (G.R. No. 45130)
Facts:
- Charge and arraignment
- On January 5, 1935, Celestino Bonoan was charged with murder for stabbing Carlos Guison on December 12, 1934, in Manila.
- The information alleged the crime was committed with evident premeditation and treachery resulting in Guison’s death three days later.
- The defendant was initially objected for arraignment due to alleged mental derangement and was confined at the Psychopathic Hospital.
- Mental examination and hospital reports
- Dr. Toribio Joson, assistant alienist, submitted a report describing the defendant’s mental condition as manic depressive psychosis, noting symptoms such as apathy, hallucinations, illusions, and intermittent speech.
- Subsequent observation by Dr. Jose A. Fernandez confirmed a diagnosis of manic depressive psychosis, concluding the defendant was mentally ill and not safe to be at large.
- Eventually, in January 1936, Dr. Fernandez declared the accused as “recovered” and fit for trial.
- Trial and verdict
- The accused pleaded not guilty and trial proceeded.
- The trial court found the defendant guilty of murder and sentenced him to life imprisonment, ordered indemnity to heirs of the deceased, and costs.
- Evidence and defense
- Prosecution witnesses, including policeman Arnoco and detective Cruz, testified that the accused clearly threatened and stabbed Guison after stating a motive involving an unpaid debt of P55.
- The defendant had prior confinement in San Lazaro Hospital for dementia praecox in 1922 and 1926.
- The defense argued that the accused was insane at the time of the crime, citing hospital diagnosis and the defendant’s mental instability.
Issues:
- Whether the accused was legally insane at the time of the commission of the murder, thus exempt from criminal liability.
- Whether the burden of proving insanity was correctly placed on the defense and whether the evidence was sufficient to establish insanity.
- Whether the lower court erred in finding the accused guilty despite evidence of mental illness.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)