G.R. No. 33877 ; February 6, 1931
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. JUAN N. GIMENA, defendant-appellant.

FACTS

The defendant, Juan N. Gimena, was charged with parricide for killing his wife, Crispina Diana. On the morning of April 9, 1930, in Ronda, Cebu, after helping his father-in-law, the defendant returned home and found his wife sleeping. Shortly after, the father-in-law heard cries for help and found the defendant attacking his wife with a bolo. The defendant was disarmed and tied up. When questioned by the justice of the peace, the defendant stated he attacked his wife because she gave money to a man he suspected of having illicit relations with her. The wife died hours later from ten wounds. The trial court convicted him of parricide, considering the mitigating circumstances of obfuscation and lack of instruction.

ISSUE

Whether the defendant’s claim that he was in a state of somnambulism (sleepwalking) when he attacked his wife constitutes a valid defense to the crime of parricide.

RULING

No. The Supreme Court affirmed the conviction. The defense of somnambulism was not proven, as medical observation of the defendant did not reveal any such condition. The Court held that, under prevailing jurisprudence, somnambulism does not constitute a defense separate from that of insanity. Since the defendant failed to prove he was insane, the defense of somnambulism could not exculpate him. The trial court’s judgment was found to be without error.

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