People v. Bascos
REITERATIONFacts
The Antecedents: The accused, Donato Bascos, was charged with the murder of Victoriano Romero. The prosecution established that Bascos killed Romero while the latter was sleeping. The defense interposed was insanity. Procedural History: The Court of First Instance of Pangasinan found the accused guilty of homicide, sentencing him to seventeen years, four months, and one day of reclusion temporal. However, the execution of the sentence was suspended, and the accused was ordered to be placed in an insane hospital, pursuant to Article 100 of the Penal Code, until his mental condition could be determined. The Petition: The accused appealed, assigning as errors the trial court's application of Article 100 of the Penal Code and its failure to apply Article 8 of the same Code. The Attorney-General concurred with the appellant's conclusion.
Issue(s)
Whether the plea of insanity is sustainable under Article 8, paragraph 1 of the Penal Code. Whether the case falls under Article 100 of the Penal Code.
Ruling
The judgment of the trial court is reversed, and the defendant is acquitted. The defendant shall be kept in confinement in the San Lazaro Hospital, or such other hospital for the insane as the Director of Health may direct, and shall not be permitted to depart therefrom without the prior approval of the Court of First Instance of the Province of Pangasinan.
Ratio Decidendi
On the plea of insanity under Article 8, paragraph 1 of the Penal Code: The Court found that the accused was a lunatic when he committed the grave felony. Evidence presented by the accused's wife and cousin, along with the examination conducted by Dr. Gonzalo Montemayor, indicated that the accused had been mentally unsound for many years and was a violent maniac. Dr. Montemayor opined that the accused was likely insane at the time of the killing. The total lack of motive for Bascos to kill Romero further supported the assumption of insanity. Consequently, under Article 8, paragraph 1 of the Penal Code, which exempts an imbecile or lunatic from criminal liability unless the latter acted during a lucid interval, the accused was deemed exempt from criminal liability. The Court emphasized that when an imbecile or lunatic commits a grave felony, the court shall order their confinement in an asylum. On the applicability of Article 100 of the Penal Code: Article 100 of the Penal Code applies when a convict becomes insane or an imbecile after final sentence has been pronounced. In this case, the defense of insanity was raised as a ground for exemption from criminal liability at the time of the commission of the offense, not as a post-conviction development. Therefore, Article 100 was not the appropriate provision to govern the situation. The trial court's application of Article 100 was deemed erroneous, as it should have considered the exemption provided by Article 8, paragraph 1, given the evidence of the accused's mental state at the time of the offense.
Main Doctrine
An accused who committed a grave felony while in a state of lunacy is exempt from criminal liability and should be confined in an asylum, as provided by Article 8, paragraph 1 of the Penal Code.