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People V Taneo

1) The defendant Potenciano Taneo was accused of wounding his wife, two visitors, and himself during a village fiesta celebration. He claimed to have been dreaming that enemies were attacking him when the acts occurred. 2) An expert witness, Dr. Serafica, testified that based on the circumstances, the defendant acted while dreaming and under the influence of hallucinations, not in his right mind. 3) The Supreme Court ruled in favor of the defendant, finding he lacked motives to commit the acts voluntarily and likely wounded his wife accidentally while dreaming he defended himself from enemies.

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Steve Rojano Arcilla
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181 views1 page

People V Taneo

1) The defendant Potenciano Taneo was accused of wounding his wife, two visitors, and himself during a village fiesta celebration. He claimed to have been dreaming that enemies were attacking him when the acts occurred. 2) An expert witness, Dr. Serafica, testified that based on the circumstances, the defendant acted while dreaming and under the influence of hallucinations, not in his right mind. 3) The Supreme Court ruled in favor of the defendant, finding he lacked motives to commit the acts voluntarily and likely wounded his wife accidentally while dreaming he defended himself from enemies.

Uploaded by

Steve Rojano Arcilla
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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People v. Taneo | G.R. No.

L-37673 | March 31, 1933


Exempting Circumstances – Insanity

Facts:
On January 16, 1932, during the celebration of the barrio’s fiesta, Potenciano Taneo went
to sleep early in the afternoon. He suddenly woke up, left his room with a bolo in hand, and upon
meeting his wife who tried to stop him, he wounded her in the abdomen. He then attacked Fred
Tanner and Luis Malinao, who were their visitors. He even tried to attack his father and after
which, he wounded himself.
The defendant, however, appealed stating that the day before the commission of the
crime, the defendant had a quarrel over a glass of "tuba" with Enrique Collantes and Valentin
Abadilla, who invited him to come down to fight, and when he was about to go down, he was
stopped by his wife and his mother. On the day of the commission of the crime, it was noted that
the defendant was sad and weak, and early in the afternoon he had a severe stomachache which
made it necessary for him to go to bed. It was then when he fell asleep. The defendant states that
when he fell asleep, he dreamed that Collantes was trying to stab him with a bolo while Abadilla
held his feet, by reason of which he got up; and as it seemed to him that his enemies were inviting
him to come down, he armed himself with a bolo and left the room. At the door, he met his wife
who seemed to say to him that she was wounded. Then he fancied seeing his wife really wounded
and in desperation wounded himself. As his enemies seemed to multiply around him, he attacked
everybody that came his way.

Issue:
Whether or not the defendant acted while in a dream.

Held/Ratio:
YES. The SC stated that the defendant acted while in a dream and his acts, with which he
is charged, were not voluntary in the sense of entailing criminal liability. Under the special
circumstances of the case, in which the victim was the defendant's own wife whom he dearly
loved, and taking into consideration the fact that the defendant tried to attack also his father, in
whose house and under whose protection he lived, besides attacking Tanner and Malinao, his
guests, whom he himself invited as may be inferred from the evidence presented, we find not only
a lack of motives for the defendant to voluntarily commit the acts complained of, but also motives
for not committing said acts.
This conclusion was supported by an expert witness in the case, Dr. Serafica, who stated
that considering the circumstances of the case, the defendant acted while in a dream, under the
influence of a hallucination and not in his right mind.
Finally, the SC stated that the wife's wound may have been inflicted accidentally. The
defendant did not dream that he was assaulting his wife, but that he was defending himself from
his enemies.

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