Case Digest (G.R. No. L-4641) Core Legal Reasoning
Core Legal Reasoning
Facts:
The case titled Leonidas Epifanio y Lazaro vs. People of the Philippines revolves around a stabbing incident that occurred on the evening of August 15, 1990, in Kilometer 7, Del Monte, Samal, Davao. The petitioner, Leonidas Epifanio y Lazaro, was accused of Frustrated Murder for attacking Crisaldo Alberto with a bladed weapon. On that night, Crisaldo and his cousin, Allan Perez, were walking home after visiting Crisaldo's father. While walking along a narrow path, Crisaldo was suddenly stabbed in the back by Leonidas, who was later identified as the attacker. After sustaining his initial wound, Crisaldo was stabbed again, this time in the left arm. Allan heard Crisaldo's cries and ran over to assist his cousin, calling out to Leonidas, which caused him to flee the scene. Crisaldo was subsequently taken first to the PeAaplata Hospital and later transferred to the Davao Medical Center, where he remained for three weeks to recover from his injuries.
A Medical Certificate
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Case Digest (G.R. No. L-4641) Expanded Legal Reasoning
Expanded Legal Reasoning
Facts:
- Parties, procedural posture, and judgments
- Petitioner: Leonidas Epifanio y Lazaro (convicted below of Frustrated Murder by the Regional Trial Court (RTC), Branch 4, Panabo, Davao, Criminal Case No. 91-15).
- Respondent: People of the Philippines. RTC convicted petitioner on July 5, 1994; Court of Appeals (CA) affirmed on May 22, 2002 (CA-G.R. CR No. 17995); CA denied motion for reconsideration on January 14, 2003. Petitioner filed a petition for review on certiorari under Rule 45 to the Supreme Court.
- Facts as found by the trial court and CA
- On August 15, 1990 at about 9:00 p.m., in Kilometer 7, Del Monte, Samal, Davao, complainant Crisaldo Alberto (Crisaldo) and his cousin Allan Perez (Allan) were walking home along a narrow path lined by shrubs (banganga). Allan walked about three meters ahead of Crisaldo.
- Crisaldo felt a piercing thrust on his back; on turning he saw the attacker identified as petitioner (also known as "Iyo/Uncle Kingkoy"). Petitioner stabbed Crisaldo again, wounding his left arm while Crisaldo attempted to defend himself.
- Allan rushed to Crisaldo when he heard his outcry, called petitioner by name ("Iyo Kingkoy") which caused petitioner to flee.
- Allan brought Crisaldo to his father’s house where his wounds were wrapped, then to PeAaplata Hospital for first aid, and finally to Davao Medical Center where Crisaldo stayed about three weeks to recuperate.
- The attending physician, Santiago Aquino, issued a medical certificate (dated September 4, 1990) describing: stab wound right scapular area (medial border) at level 5–7th intercostal space; left arm medial aspect; fracture 7th and 8th right posterior rib; probable healing time 15–30 days barring complication. No testimony of the attending physician on the mortal or life-threatening nature of the wounds was presented at trial.
- Petitioner’s alibi/defense and charge
- Petitioner pleaded not guilty. His defense was essentially a denial and alibi: he claimed to have harvested coconuts in Anonang earlier on August 15, returned home, slept, and was later roused to assist when someone had been hacked; he accompanied the victim to the hospital and reported the incident to barangay officials; policemen later visited his home identifying him as a suspect; he was detained but not formally investigated and then released to go home.
- Information (January 4, 1991) charged petitioner with Frustrated Murder alleging treachery and evident premeditation, intent to kill, and that the accused performed all acts of execution which would produce murder but for timely medical assistance.
- Trial, appeals, and issues presented to the Supreme Court
- RTC convicted petitioner of Frustrated Murder and sentenced him to six years and one day to ten years prision mayor and ordered payment of P6,000 indemnity.
- CA affirmed RTC decision. Petitioner appealed to the Supreme Court, raising principally whether his guilt for Frustrated Murder was proven beyond reasonable doubt and seeking reclassification to the lesser offense of Attempted Murder based largely on absence of proof that the wounds were life-threatening.
- Office of the Solicitor General (OSG) maintained that (a) petitioner performed all the acts of execution so the crime is frustrated murder; (b) non-presentation of the doctor was not raised below and should not now be entertained; and (c) duration of hospitalization is not determinative of fatality of wounds.
Issues:
- Primary legal issues presented
- Whether petitioner’s conviction for Frustrated Murder was proven beyond reasonable doubt or whether the evidence supports conviction for the lesser offense of Attempted Murder.
- Whether the prosecution met its burden to establish that the wounds inflicted were mortal (i.e., would have caused death absent timely medical intervention), given that the attending physician was not presented to testify and only a medical certificate was offered.
- Ancillary or procedural issues relevant to disposition
- Whether petitioner was procedurally barred from raising the failure to present the doctor on appeal because it was not raised as an issue before the RTC.
- Whether the award of actual damages (P6,000 in the RTC decision) was supported by evidence of medical expenses and, if not, whether temperate damages should be awarded.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)