Case Summary (G.R. No. 37673)
Petitioner
The People of the Philippine Islands
Respondent
Potenciano Taneo
Key Dates
Crime: January 16, 1932
Decision: March 31, 1933
Applicable Law
Criminal responsibility under the Philippine legal system then governed by the Jones Law (Philippine Autonomy Act) and prevailing penal statutes; defenses for non voluntariness and insanity.
Facts and Circumstances of the Incident
During a fiesta celebration on January 16, 1932, Taneo, suffering severe stomach pain, lay down to sleep in the afternoon. While asleep he abruptly rose, armed with a bolo. His wife attempted to restrain him at the door, and he sustained or inflicted a wound on her abdomen. He then attacked Tanner and Malinao, and attempted to assault his father before inflicting a wound on himself.
Defendant’s Hallucinations and Actions
Taneo maintained that he dreamed Collantes and Abadilla were assaulting him—one stabbing him with a bolo and the other holding his feet. Believing these figures to be real, he armed himself and fled the room. Encountering his wife, he imagined she had been wounded by his enemies, and in desperation wounded himself. He then attacked any person he perceived as a threat.
Lack of Motive and Character Evidence
Evidence showed no prior disputes between Taneo and his wife, Tanner, or Malinao; on the contrary, he loved his wife and had invited the guests. His relationship with his father was familial, and there was no indication of animus. The absence of a reasonable motive, coupled with affection for his wife and duty to his host family, suggested his violent acts were involuntary.
Expert Testimony on Insanity
Dr. Serafica, expert witness, concluded that Taneo acted under an hallucination while asleep and was not in his right mind. The doctor attributed his conduct to a dream-induced mental disturbance negating voluntary criminal intent.
Uncertainty Regarding the Wounding of the Wife
No eyewitness testified to Taneo’s infliction of his wife’s wound. The w
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Facts of the Case
- Potenciano Taneo resided with his wife in his parents’ house in barrio Dolores, Ormoc, Leyte.
- On January 16, 1932, during a barrio fiesta in Dolores, visitors including Fred Tanner and Luis Malinao were entertained at the Taneo home.
- Early that afternoon, Taneo experienced severe stomach pain, went to bed, and fell asleep.
- In his sleep he suddenly awoke, armed himself with a bolo, and emerged from the room.
- At the doorway he encountered his wife, who he believed was wounded; in panic he wounded himself and then attacked several persons in the house, including Fred Tanner, Luis Malinao, and attempted to assault his father.
- The wife, then seven months pregnant, died five days later from her abdominal wound; the foetus was also asphyxiated and perished.
Procedural History
- The People filed an information charging Potenciano Taneo with parricide.
- Upon conviction, the trial court imposed reclusion perpetua, accessory penalties, indemnity of ₱500 to the heirs of the deceased, and costs.
- Taneo appealed the conviction to the Supreme Court.
Prior Circumstances and Mental State
- The day before the incident, Taneo quarreled over a glass of “tuba” with Enrique Collantes and Valentin Abadilla, who challenged him to fight; his wife and mother restrained him.
- On the day of the crime Taneo appeared sad, weak, and suffe