People v. Bonoan (February 17, 1937) Ponente: Laurel, J. FACTS: 12 Dec.

1934 Celestino Bonoan met Carlos Guison on Avenida Rizal near a barbershop close to Toms Dixie Kitchen. Francisco Beech, who was at the time in the barbershop, heard Bonoan say in Tagalog, I will kill you. Beech turned around & saw Bonoan withdrawing his right hand, w/c held a knife, from the side of Guison who said, I will pay you, but Bonoan simply replied saying that he would kill him & then stabbed Guison 3 times on the left side. The incident was witnessed by policeman Damaso Arnoco. Bonoan was arrested on the day itself. Bonoan admitted to stabbing Guison. Guison was taken to PGH where he died 2 days later. 5 January 1935 Prosecuting attorney of Manila filed an information charging Celestino Bonoan with the crime of murder. 16 January 1935 Bonoans defense counsel objected to the arraignment on the ground that the defendant was mentally deranged and was at the time confined in the psychopathic hospital. The court issued and order requiring the Director of the hospital to report on Bonoans mental condition. A report was rendered by Dr. Toribio Joson. 23 March 1935 the case was called for arraignment again, the defense objected and again the court filed another order requiring the doctor who examined Bonoan to appear in court to report on Bonoans mental condition. 26 March 1935 Dr. Toribio appeared before the court for the inquiry. The court issued another order asking to summon other doctors from the hospital and to put Bonoan under another doctor, Dr. Jose Fernandez, for closer observation. Dr. Fernandez filed his report on 11 June 1935. 28 June 1935 the case was called again, Dr Fernandez showed up in court and reported that Bonoan was still not in a condition to defend himself. 21 January 1936 Dr. Fernandez reported to the court that Bonoan could be discharged from the hospital and appear for trial as he was considered a recovered case. 27 February 1936 Bonoan was arraigned and pleaded not guilty and the trial was held. To prove motive and mental normalcy of Bonoan the prosecution called on Damaso Arnoco who testified that the reason for Bonoans attack was that Guison owed him P55 and would not pay him back. Bonoan had bought the knife with which he stabbed Guison for 50 centavos and had been waiting 2 days to kill him. He acquired this information when he arrested and questioned Bonoan. Bonoan was charged with the murder of Carlos Guison, and sentenced him to life imprisonment and to pay P1K to indemnify the heirs of Guison. The defendant appealed the case and his counsel cited that the lower court had erred in finding that Bonoan had dementia intermittently and not immediately prior to the commission of the offense, in finding that the accused did not show any abnormality either in behavior, action, language, appearance, or action that he was mentally deranged, in finding that the burden of proof lay in the defendant to prove that he was mentally deranged at the time of the crime, and in not acquitting Bonoan.

ISSUE: WON Bonoan was insane at the time of the commission of the crime. HELD: Yes. There are 3 different theories used (1) Insanity as a defense in a confession and avoidance and as such must be proved beyond reasonable doubt. Proof of insanity at the time of committing the criminal act should be clear and satisfactory in order to acquit the accused on the ground of insanity. (Philippines uses this) (2) That an affirmative verdict of insanity is to be governed by preponderance of evidence, and in this view, insanity is not to be established beyond a reasonable doubt. (3) Prosecution must prove sanity beyond a reasonable doubt. When a defendant in a criminal case interposes the defense of mental incapacity, the burden of establishing the fact rests upon the defendant. To prove insanity the evidence must be clear and convincing. The courts need to distinguish insanity in law from passion or eccentricity, mental weakness or mere depression resulting from physical ailment. In the separate reports given by Dr. Toribio Joson and Dr. Fernandez they both diagnosed Bonoan to be unstable, stating that he will always have troubles and diff iculties with this world of realities. Bonoan was diagnosed with dementia praecox which is a mental disease that disqualifies a person from legal responsibility for his actions. In these people homicidal attacks are common because of the delusions that they are being interfered with or that their property is being taken. The court was of the opinion that Bonoan was demented at the time he perpetrated the serious offense charge with and that consequently he is exempt from criminal liability. Disposition: Judgment of the lower court REVERSED. Defendant appellant ACQUITTED but to be kept in confinement in the San Lazaro Hospital or any other hospital for the insane.