Case Digest (G.R. No. L-57535) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippine Islands v. Potenciano Taneo, G.R. No. 37673, decided on March 31, 1933, the appellant Potenciano Taneo resided with his wife in his parents’ home in Dolores, Ormoc, Leyte. During a barrio fiesta on January 16, 1932, visitors including Fred Tanner and Luis Malinao were entertained in the house. Early that afternoon, Taneo, feeling unwell and with a severe stomachache, lay down and fell asleep. While asleep he suddenly arose with a bolo in hand and, in a state of hallucination, injured his seven-months-pregnant wife in the abdomen. He then attacked Tanner, Malinao, and even attempted to assault his own father, before wounding himself in apparent desperation. His wife died five days later, along with the asphyxiated foetus. An information for parricide was filed, and the trial court convicted Taneo, sentencing him to reclusion perpetua, accessory penalties, indemnity of P500 to the heirs of the deceased, and cos Case Digest (G.R. No. L-57535) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Potenciano Taneo resided with his wife and parents in Barrio Dolores, Ormoc, Leyte.
- On January 16, 1932, a barrio fiesta was held; among the visitors entertained in the Taneo household were Fred Tanner and Luis Malinao.
- Events Leading to the Incident
- The day before, Taneo quarrelled over a glass of “tuba” with Enrique Collantes and Valentin Abadilla; his wife and mother prevented him from going to fight them.
- On the afternoon of the fiesta, Taneo, described as sad, weak, and suffering stomachache, went to bed and fell asleep.
- The Incident
- While asleep, Taneo dreamed Collantes was about to stab him as Abadilla held his feet; he awoke, armed himself with a bolo, and left the room.
- At the doorway he encountered his wife, whom he imagined wounded; in desperation he stabbed himself and then attacked his wife, Tanner, Malinao, and even attempted to assault his father.
- His wife, seven months pregnant, died five days later from the abdominal wound; the foetus was also lost.
- Procedural History
- An information for parricide was filed; the trial court convicted Taneo and sentenced him to reclusion perpetua with accessory penalties, P500 indemnity to heirs, and costs.
- Taneo appealed the conviction to the Supreme Court.
Issues:
- Whether the acts of Taneo were voluntary, thus constituting a criminal offense of parricide.
- Whether Taneo’s mental state—specifically dreaming or hallucination—negated his criminal liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)