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PEOPLE v. TANEO [58 Phil.

255 (1933)]

Facts: Potenciano Taneo and his wife lived in his parent's house in Dolores, Ormoc. On January 16,
1932, a fiesta was being celebrated in the said barrio and guests were entertained in the house, among
them were Fred Tanner and Luis Malinao. Early that afternoon, Potenciano went to sleep and while
sleeping, he suddenly got up, left the room bolo in hand and, upon meeting his wife who tried to stop
him, wounded her in the abdomen. He also attacked Fred and Luis and tried to attack his father, after
which, he wounded himself. Potenciano's wife, who was 7 months pregnant at that time, died five days
later as a result of the wound.

The trial court found Potenciano guilty of parricide and was sentenced to reclusion perpetua.

It appears from the evidence that the day before the commission of the crime, the defendant had a
quarrel over a glass of "tuba" with Collantes and Abadilla, who invited him to come down and fight.
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, had a severe stomachache
that's why he went to bed in the early afternoon. The defendant stated that when he fell asleep, he
dreamed that Collantes was trying to stab him with a bolo while Abadila held his feet. That's why he got
up and 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: WON defendant acted while in a dream.

Ratio: Yes. The defendant acted while in a dream & his acts, therefore, werent voluntary in the sense
of entailing criminal liability.

The apparent lack of motive for committing a criminal act does not necessarily mean that there are
none, but that simply they are not known to us. Although an extreme moral perversion may lead a man
to commit a crime without a real motive but just for the sake of committing it. In the case at hand, the
court found not only lack of motives for the defendant to voluntarily commit the acts complained of
(read: he loved his wife dearly, he tried to attack his father in whose house the lived and the guests
whom he invited), but also motives for not committing the acts.

Dr. Serafica, an expert witness in the case, 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.

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.

Judgment: defendant not criminally liable for the offense. It was also ordered that he be confined in the
government insane asylum and will not be released until the director thereof finds that his liberty would
no longer constitute a menace

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