G.R. No. 45130 – People v.
Bonoan (1937) o The SC also notes the danger of indulging in the
Laurel, J.
FACTS
1. Dec. 12, 1934: Defendant Celestino Bonoan met the deceased
Carlos Guison.
 According to witnesses, Bonoan said to Guison in Tagalog
"I will kill you", to which Guison replied in Tagalog "I will pay
you", but Bonoan replied the same phrase and stabbed
Guison thrice on the left side.
2. The court called for the arraignment of the accused on Jan. 16, Mar.
23, and Jun. 28, 1935, but Bonoan was confined in the
Psychopathic Hospital and was said to be not in a condition to
defend himself.
 The trial court called some doctors of the Psychopathic
Hospital for questioning, after which it issued an order
directing that Bonoan be placed under the chief alienist or
an assistant alienist of the hospital for a personal
examination as to his mental condition.
3. Jan. 21, 1936: Dr. Jose A. Fernandez, assistant alienist of the
hospital, reported to the court that defendant could be discharged
from the hospital and appear for trial as he was "considered a
recovered case". Arraignment and trial were then conducted.
4. After trial, the lower court found Bonoan guilty of murder and
sentenced him to life imprisonment, to indemnify the heirs of the
deceased P1,000.00, and to pay the costs.
ISSUE with HOLDING
1. W/N Bonoan was demented at the time of the commission of
the crime – Yes.
 The killing of the deceased by the defendant is already
admitted.
 In the Philippines, the court has approximated the stricter
view that insanity as a defense must be proven beyond
reasonable doubt.
o The burden of establishing the fact rests upon the
defendant who raised the defense of mental
incapacity.
o To prove insanity, circumstantial evidence, if clear
and convincing, may suffice.
presumption of continuity in cases of temporary or
spasmodic insanity in relation to the decision made
by the lower court.
 The majority of the court heavily considered the following
facts:
o Bonoan’s confinement in the insane department of
the San Lazaro Hospital during the periods from Apr.
11 to 26, 1992 and Jan. 6 to 10, 1926 suffering from
dementia praecox shows that the recurrence of the
ailment at the time of occurence of the crime is
rationally and scientifically possible.
o The SC cites from relevant books that all persons
suffering from dementia praecox are clearly to be
regarded as having mental disease to a degree that
disqualifies them from legal responsibility for their
actions.
 The court further expounds on this by citing
Dr. Elias Domingo, chief alienist of the
Insular Psychopathic Hospital, that the
symptoms of dementia praecox, in certain
periods of excitement, are similar to those of
manic depressive psychosis, and that in
either case the mind appears "deteriorated"
because during said period, the person has
no control whatever of his acts.
o Dr. Celedonio S. Francisco testified that defendant
had an attack of insomnia for 4 days prior to the day
of the crime. Insomnia is one of the symptoms of,
and may lead to, dementia praecox.
o Bonoan was sent by the police to the Psychopathic
Hospital the day following the commission of the
crime is an indication that the police officers
themselves doubted the mental normalcy of the
accused.
o The report of Dr. Toribio Jonson on Jan. 15, 1935,
made within the first month of treatment, concluded
that Bonoan was suffering from a form of psychosis,
called manic depressive psychosis.
 o A subsequent report on Jun. 11, 1935 by Dr. Jose A.
Fernandez concluded that Bonoan is not safe to be
at large, and that he will always have troubles and
difficulties with the world of realities.
 The SC said that the testimonies of the policemen Damaso
Arnoco and Benjamin Cruz where Bonoan said that
deceased Guinson owed him P55.00 and would not pay,
and that he bought a knife and he watched the deceased for
2 days in order to kill him, is not necessarily proof of the
sanity of the accused during the commission of the crime.
o The SC cited Dr. Sydney Smith in that in a type of
dementia praecox, the crime is usually preceded by
much complaining and planning.
 Bonoan was demented at the time he perpetuated the
crime, which exempts him from criminal liability.

DISPOSITIVE PORTION
Lower court reversed. Bonoan is acquitted, and shall be kept in
confinement in the San Lazaro Hospital or such other hospital for the
insane until the Court of First Instance of Manila shall otherwise order
or decree.