Title
Isidoro Mondragon vs. People
Case
G. R. No. 1-17666
Decision Date
Jun 30, 1966
A 1954 altercation over a rice field dike led to a bolo fight between Serapion Nacionales and Isidoro Mondragon. Mondragon was initially convicted of attempted homicide, but the Supreme Court ruled his intent to kill was unproven, reducing his charge to less serious physical injuries.
A

Case Digest (G. R. No. 1-17666)

Facts:

Isidoro Mondragon v. The People of the Philippines, G.R. No. 1-17666, June 30, 1966, the Supreme Court En Banc, Zaldivar, J., writing for the Court.

The petitioner, Isidoro Mondragon, was prosecuted in the Court of First Instance of Iloilo for the crime of frustrated homicide. After trial that court found him guilty instead of frustrated homicide of the lesser offense of attempted homicide and imposed an indeterminate prison term (as stated in the record) with the accessory penalties and costs.

Mondragon appealed to the Court of Appeals, which affirmed the trial court's conviction for attempted homicide in all respects. The Court of Appeals’ findings, as reproduced in the Supreme Court record, described an affray on July 11, 1954: while complainant Serapion Nacionales was opening a dike in his ricefield, Mondragon approached, struck first with his fist, then drew a bolo and inflicted several incised wounds on Nacionales; Nacionales in turn drew his bolo and hacked Mondragon. A municipal health officer certified multiple incised wounds to Nacionales that were “not necessarily fatal” and would heal in 20–25 days absent complications.

Mondragon filed a petition for certiorari to review the Court of Appeals decision; no brief for the respondent, The People of the Philippines, was filed by the Solicitor General. The Court of Appeals had inferred intent to kill from the petitioner’s trial testimony—an affirmative answer to whether he “would do everything [he] could to stop Nacionales digging the canal because [he] needed the water.” The Supreme Court granted review and considered whether that inference and the other facts supported conviction for attempted (or frustrated) homicide rather than a lesser physical injuries offense.

Issues:

  • Did the Court of Appeals err in finding the petitioner guilty of the crime of attempted homicide rather than a lesser offense?
  • Was the petitioner’s alleged intent to kill established beyond reasonable doubt by the evidence, including his affirmative trial answer that he would “do everything” to stop Nacionales?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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