GR 37673; (March, 1933) (Digest)
G.R. No. 37673 ; March 31, 1933
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. POTENCIANO TANEO, defendant-appellant.
FACTS
Potenciano Taneo lived with his wife in his parents’ house. During a barrio fiesta, after suffering a stomachache and going to sleep, he suddenly got up armed with a bolo. He wounded his wife (who was seven months pregnant, later dying from the injury), attacked two guests, tried to attack his father, and then wounded himself. The defendant claimed he was acting in a dream where he was being attacked by persons with whom he had a quarrel the previous day. The evidence showed he dearly loved his wife and had no motive to harm her or the guests. An expert witness, Dr. Serafica, opined the defendant acted while in a dream, under hallucination, and not in his right mind.
ISSUE
Whether the defendant is criminally liable for the killing of his wife (parricide) given the circumstances of his mental state.
RULING
No. The Supreme Court found the defendant acted while in a dream and his acts were not voluntary in the sense of entailing criminal liability. Considering the lack of motive, his love for his wife, and the expert medical opinion, the Court concluded he was not criminally responsible. The appealed judgment was reversed. Instead of criminal penalty, the Court ordered his confinement in the Government insane asylum until his liberty would no longer constitute a menace.
AI Generated by Armztrong.