G.R. No. 120344 - Paddayuman vs. People

On July 24, 1991, an Information for frustrated murder was filed against Florentino Paddayuman, alleging an attack on March 15, 1991, in Tuguegarao, Cagayan.
The Information charged that Paddayuman, armed with a sharp, pointed bladed instrument, attacked his victim, Maximo Quilang, with evident premeditation and treachery.

During a drinking session at the house of Casimiro Paddayuman in Barangay Capatan, tensions arose between Paddayuman and Quilang.
After admonishing the accused for drinking too much, Maximo left the session around midnight.
On his way home, approximately 100 meters from Casimiro’s house, the accused stabbed Maximo at the left side of his body.
The accused allegedly declared, “I will really kill you,” and proceeded to stab Maximo a second time at the chest.
Despite the attack, Maximo managed to call for help, and his nephew, Apolinario Dassil, came to his aid by transporting him to the Cagayan Valley Regional Hospital.

Dr. Cirilo M. Pintucan examined and treated Maximo Quilang on March 16, 1991, identifying two stab wounds: one at the fourth intercostal space near the sternal region, and the other on the lateral portion of the left chest below the nipple line.
The Medico-Legal Certificate noted a diagnosis of multiple penetrating stab wounds and a pneumothorax, with a need for medical attention for a period “not more than 1 month barring complications.”
Maximo was hospitalized for a total of nine days, confirming that the wounds were serious but non-fatal.

Paddayuman pleaded not guilty and interposed a plea of self-defense.
He testified that on the morning of March 15, 1991, he went to Casimiro’s house to help prepare for a wedding and later returned home.
At midnight, he was startled by the barking of dogs and saw Maximo setting his granary on fire.
The accused claimed that when he confronted Maximo about the burning, Maximo threatened him by reaching into his back pockets for a weapon, prompting Paddayuman to stab him.
Supportive evidence for the granary incident included testimonies from Casimiro Paddayuman and Barangay Tanod Romeo Macanang, who acknowledged a burning incident but did not attribute it to Maximo Quilang.
Additionally, on June 13, 1991, Paddayuman filed a criminal complaint for destructive arson against Maximo and Apolinario Dassil, though the case was dismissed due to lack of probable cause.

At trial, the prosecution relied on the testimonies of Maximo Quilang, Apolinario Dassil, and Dr. Pintucan.
The Trial Court convicted Florentino Paddayuman of attempted homicide, noting that although the acts executed would have resulted in murder absent timely medical intervention, the prosecution failed to prove the accompanying qualifiers of treachery and evident premeditation.
Paddayuman was sentenced to a term ranging from six (6) months of arresto mayor (minimum) to two (2) years, four (4) months and one (1) day of prision correccional (maximum) and was ordered to pay damages to the victim.
The Court of Appeals, in its decision dated April 26, 1995, affirmed the RTC’s judgment.
The Supreme Court, denying the petition for review on certiorari, ultimately affirmed the conviction in toto.

Whether Paddayuman’s act of stabbing Quilang can be justified under the plea of self-defense.
Whether he met the three essential requisites of self-defense: an act of unlawful aggression, reasonable necessity in employing force, and lack of sufficient provocation.

Whether the evidence, including the timing and details of the alleged burning incident, sufficiently established that Maximo Quilang posed an imminent threat.
Whether the testimonies of defense witnesses, who confirmed only the burning of the granary without attributing it to Quilang, undermined Paddayuman’s claim.

Whether the prosecution’s evidence, particularly the medical testimony and the circumstances surrounding the sword’s use, proved an intention to kill.
Whether the crime committed should be classified as attempted homicide as opposed to murder, given the non-fatal nature of the injuries inflicted on Quilang.