GR L 5900; (December, 1910) (Digest)
G.R. No. L-5900
THE UNITED STATES, plaintiff-appellee, vs. RAMON HONTIVEROS CARMONA, defendant-appellant.
December 22, 1910
FACTS: Ramon Hontiveros Carmona, following a dispute with his mother-in-law (Potenciana Sales) and accusations of infidelity against his wife (Maria Fuentes), assaulted his wife, their nine-month-old child, two sisters-in-law (Isabel and Eusebia Fuentes), his mother-in-law, and a servant (Felipa Lacro) with a bolo on October 3, 1908. The victims sustained various injuries: Maria received head and shoulder wounds (her child also lightly wounded); Isabel had a left jaw wound; Eusebia, a left forearm and elbow wound; Potenciana, a neck wound; and Felipa, a severed left earlobe causing visible deformity. The injuries required varying periods of medical attention, with Felipa’s wound causing a visible deformity and Maria’s head wound poorly healed.
Carmona was charged with lesiones graves (serious physical injuries). The Court of First Instance (CFI) found him guilty and sentenced him to eight months of prision correccional, P25 indemnity to Felipa Lacro, subsidiary imprisonment, and costs.
Carmona appealed, claiming he was suffering from fever and was out of his mind and unconscious during the incident, thus denying any knowledge or motive for his actions. His counsel argued that he acted in a paroxysm due to his mental state, without any motive.
ISSUE: Whether the defendant’s claim of temporary insanity or unconsciousness due to fever, at the time of committing the physical injuries, exempts him from criminal liability.
RULING: The Supreme Court AFFIRMED the CFI’s decision.
The Court held that acts penalized by law are always considered voluntary unless the contrary is proven. The defendant’s claim of temporary insanity or unconsciousness due to fever at the time of the crime was not sufficiently established. There was no full proof that he was deprived of reason or lacked complete consciousness during the assault. The physicians who examined him nine days after the incident could not definitively state that he was insane at the time of the assault. Their mere opinions, expressed in hypothetical terms, and the suggestion of a family history of insanity, were deemed insufficient to prove that the defendant was insane when the crime was committed.
Therefore, the defendant was presumed to be in a normal mental condition and was criminally liable for his actions.
While no aggravating circumstances were found, the Court recognized the extenuating circumstance of having acted under the impulse of jealousy (Article 9, No. 7 of the Penal Code). Consequently, the penalty of prision correccional in its minimum and medium degrees for lesiones graves was imposed in its minimum degree. The defendant was also sentenced to the accessory penalties prescribed by Article 61 of the Penal Code and costs.
