People vs.

Ambal
GR NO. L-52688 OCT. 17, 1980
FACT!
Honorato Ambal was married with Felicula for 15 yrs. She appeared to be a shrew
and neglectful wife. She stayed away from the conjugal home at times. He killed her
when the latter failed to buy a medicine for Ambal who was aficted with inuen!a.
"he two engaged in a heated altercation. Felicula told her husband that it would be
better if he were dead. "hat remark infuriated Ambal and impelled him to attack his
wife.
He went to the barangay captain and informed that he killed his wife. After making
that oral confession# Ambal took a pedicab# went to the municipal hall and
surrendered to a policeman.
$uring the trial# he pleaded not guilty and# thru his counsel de o%cio# the defense of
Ambal was insanity. $r. &albas stated during trial' &efore the commission of the
crime# he was normal. After the commission of the crime# normal# but during the
commission of the crime# that is what we call ()sychosis* due to short frustration
tolerance.
"he +ourt of First ,nstance of +amiguin con-icted him of parricide# sentencing him
to reclusion perpetua and ordering him to pay an indemnity of )hp1.#/// to the
heirs of his deceased wife# Felicula 0icente1Ambal.
"#$'
2hether or not Ambal was insane and is not guilty of the crime of parricide.
R#L"NG'
Art. 1. of the 3e-ised )enal +ode e4empts from criminal liability an imbecile or an
insane person unless the latter has acted during a lucid inter-al. "he law presumes
that e-ery person is of sound mind# in the absence of proof to the contrary 56S -s.
7artine!# 89 )hil 8/5:. "he law always presumes all acts to be -oluntary. ,t is
improper to presume that acts were e4ecuted unconsciously. ,n order that insanity
may be taken as an e4empting circumstance# there must be complete depri-ation of
intelligence in the commission of the act or that the accused acted without the least
discernment. 7ere abnormality of his mental faculties does not e4clude imputability.
Ambal is guilty of parricide with the mitigating circumstance of -oluntary surrender
to the authorities. Article .9; of the 3e-ised )enal +ode punishes parricide with
reclusion perpetua to death. "he lesser penalty should be imposed because of the
presence of one mitigating circumstance and that absence of aggra-ating
circumstance
People vs. Fo%m&'o(es )87 P*&l. 658+
Fa,-s'
,n the month of <o-ember 1=9;# Abelardo was li-ing on his farm in +amarines Sur
with his wife# >ulia Agricola and their 5 children. From there they transferred in the
house of his half1brother# ?acarias Formigones in the same municipality to %nd
employment as har-esters of palay. After a month# >ulia was sitting at the head of
the stairs of the house when Abelardo# without pre-ious @uarrel or pro-ocation
whatsoe-er# took his bofo from the wall of the house and stabbed his wife >ulia# in
the back# the blade penetrating the right lung and causing a se-ere hemorrhage
resulting in her death. Abelardo then took his dead wife and laid her on the oor of
the li-ing room and then lay down beside her. ,n this position# he was found by the
people who came in response to the shouts made by his eldest daughter# ,rene
Formigones.
"he moti-e was admittedly that of jealousy because according to his statement# he
used to ha-e @uarrels with his wife for reason that he often saw her in the company
of his brother# ?acariasA that he suspected the two were maintaining illicit relations
because he noticed that his wife had become indiBerent to him. $uring the
preliminary in-estigation# the accused pleaded guilty. At the case in the +ourts of
First ,nstance# he also pleaded guilty but did not testify. His counsel presented the
testimony of two guards of the pro-incial jail where Abelardo was con%ned to the
eBect that his conduct was rather strange and that he beha-ed like an insane
person# at times he would remain silent# walk around stark naked# refuse to take a
bath and was his clothes etc... "he appeal is based merely on the theory that the
appellant is an ,7&C+,DC and therefore e4empt from criminal liability under article
1. of the 3)+.
"ss.e'
2hether or not Abelardo is an imbecile at the time of the commission of the crime
and therefore e4empted from criminal liability
/el0'
<o. He is not an imbecile. According $r. Francisco Eomes# he was suBering only
from feeblemindedness and not imbecility and that he could distinguish between
right and wrong. ,n order that a person could be regarded as an imbecile within the
meaning of article 1. of the 3)+ so as to be e4empt from criminal liability# he must
be depri-ed completely of reason or discernment and freedom of will at the time of
committing the crime.
As to the strange beha-ior of the accused during his con%nement# assuming it was
not feigned to stimulate insanityA it may be attributed either to his being
feebleminded or eccentric# or to a morbid mental condition produced by remorse at
ha-ing killed his wife. A man who could feel the pangs of jealousy and take -iolent
measures to the e4tent of killing his wife who he suspected of being unfaithful to
him# in the belief that in doing so# he was -indicating his honor# could hardly be
regarded as an imbecile. 2hether or not the suspicions were justi%ed# is of little or
no importance. "he fact is that he belie-ed her faithless. Furthermore# in his written
statement# he readily admitted that he killed his wife# and at the trial he made no
eBort to deny of repudiate said written statements# thus sa-ing the go-ernment all
the trouble and e4pense of catching him and securing his con-iction.
"here are howe-er . mitigating circumstances present'
1: )assion or obfuscation 5ha-ing killed his wife in a jealous rage:
.: Feeblemindedness
,n conclusion# the appellant is found guilty of parricide and the judgment of the
lower court is hereby aFrmed with the modi%cation that he appellant will be
credited with one1half of any pre-enti-e imprisonment he has undergone 5because
of the . mitigating circumstances:
People v. G&me(a
Fa,-s!
After cleaning bamboo with his father in law 5Eregorio $iana:# Eimena went home
and upon arri-ing there he found his wife +rispina $iana and a child . weeks of age
sleeping together on the oor. Shortly afterwards father of +rispina# Eregorio $iana
who happened to li-e near the house of Eimena heard +rispina crying for help. He
went to the EimenaGs house and there found the defendant attacking +rispina with
a bolo. 2ith the assistance of "eodulo Eimena# a brother of the defendant# Eregorio
succeeded in disarming the defendant and tied him to a post of the house. "hat
incident was reported to the authority# and as the in-estigation was conducted they
found out that Eimena was suspecting his wife of ha-ing an illicit relationship with
one Apolinar Sereno.
&ecause of the wounds inicted to +rispina# she e-entually die.
"ss.e'
2hether or not Eimena is e4empt from incurring liability for the death of +rispina.
/el0'
Hes.
"he argument of Eimena that he was in the state of somnambulism when he
attacked his wife the court do not think that this theory can ser-e as a defense in
the present case. &y order of the trial court the defendant was placed under
obser-ation for some time by $r. Duis &. Eome!# but the doctor apparently did not
disco-er any somnambulism on the part of the defendant. A defense of that
character must be pro-en and such proof is lacking in this case.
"he defense that the oBense charged was committed by the accused during the
pre-alence of or in a state of somnambulism has been recogni!edA but the latest
holding of courts is to the eBect that it does not constitute a defense other than that
embraced in a plea of insanity.
P$OPL$ 1 2ONOAN
Fa,-s!
+elestino &onoan is charged with the crime of murder for stabbing +arlos Euison
with a knife# which caused his death three days afterwards. An arraignment was
then called# but the defense objected on the ground that the defendant was
mentally deranged and was at the time con%ned at the )sychopatic Hospital. After
se-eral months of summons for doctors# production of the defendantGs complete
record of mental condition from the hospital and defendantGs admission to the
hospital for personal obser-ation# assistant alienist $r. >ose Fernande! %nally
reported to the court that &onoan may be discharged for being a (reco-ered case*.
After trial# the lower court found &onoan guilty and sentenced him to life
imprisonment.
"he defense now appeals# claiming the lower court made errors in %nding &onoan
suBered dementia only occasionally and intermittently# did not show any kind of
abnormality# that the defense did not establish the defendantGs insanity and %nding
accused guilty.
"ss.e'
2I< &onoan is e4empt for ha-ing criminal liability
/el0!
Hes. "he +ourt %nds the accused demented at the time he perpetrated the crime#
which conse@uently e4empts him from criminal liability# and orders for his
con%nement in San Da!aro Hospital or other hospital for the insane. "his ruling was
based on the following e-idence'
6ncontradicted e-idence that accused was con%ned in the insane department of
San Da!aro Hospital and diagnosed with dementia praeco4 long before the
commission of the oBense and recurrence of ailments were not entirely lacking of
scienti%c foundation
)ersons with dementia praeco4 are dis@uali%ed from legal responsibility because
they ha-e no control of their actsA dementia praeco4 symptoms similar to manic
depression psychosis
Accused had an insomnia attack# a symptom leading to dementia praeco4# four
days prior to act according to $r. Francisco
Accused was sent the )sychopatic hospital on the same day of crime and arrest#
indicating the policeGs doubt of his mental normalcy.
$efendant suBered from manic depressi-e psychosis according to $r. >oson