G.R. No. 39552 - People vs. De la Cruz

The defendant, Lorenzo de la Cruz, was charged with the crime of frustrated murder for an attack committed on November 23, 1932, in the municipality of Aliaga, Province of Nueva Ecija, Philippine Islands.
The primary motive alleged was the defendant’s belief that the victim, Raymundo Calderon—the chief of police of Aliaga—was involved with Pastora Acebron, the concubine the defendant was determined to keep for himself.

On November 23, 1932, at approximately 8:30 a.m., as Raymundo Calderon was descending the stairway of the municipal building, the defendant attacked him from behind with a knife (identified as Exhibit A).
The assault was sudden and unexpected, with no exchange of words preceding the attack.
The method of attack employed treachery, catching the victim unaware and thereby ensuring that no immediate defensive action could be made.

Immediately after being stabbed, Calderon collapsed and fell down the stairway, which led to further complications.
Initial medical attention was rendered at the municipal dispensary followed by subsequent treatment:

He was first examined and partly sutured by Dr. Marcelo Medina.
After partially suturing the wound, Calderon vomited blood approximately thirty minutes later, indicating the gravity of his injury.

To Cabanatuan Hospital on December 8, 1932, where he was noted to have severe symptoms including weakness, fever, and difficulty breathing due to the wound’s effect on his right lung.
Subsequently, he was taken to Saint Paul’s Hospital in Manila on December 9, 1932, where further diagnostic procedures (including a radiograph) prompted an immediate surgical intervention to remove bloody serum from his pleural cavity.

Hospitalization lasted until December 24, 1932, and although Calderon’s wound eventually healed, his recovery was protracted, and he was advised against resuming labor immediately.
Economic impact included:

Loss of salary (P40 monthly) from November 23, 1932, to February 1, 1933, when he resumed work.
Incurrence of medical expenses totaling P800 for the treatment of his injuries.

At arraignment, the defendant pleaded not guilty but later waived his right to present any evidence on his behalf.
A sworn statement made by the defendant before the justice of the peace (Exhibit B) was introduced as part of the trial record.
The lower court established that the defendant performed all the acts of execution required for a murder, yet the death of the victim did not occur solely due to an intervening cause—namely, the timely and effective medical treatment that saved Calderon’s life.

The defendant was charged and subsequently convicted of frustrated murder.
The imposition of a qualifying circumstance—treachery—was based on the defendant’s method of attack from behind, which ensured that the victim was caught unaware.
The court sentenced de la Cruz to suffer twelve years and one day of reclusion temporal and ordered him to pay Raymundo Calderon indemnification in the sum of P890.64.
On appeal, the defendant contended that he should have been convicted merely of the crime of serious physical injuries (under the Revised Penal Code), citing insufficient evidence of the intent to kill necessary for frustrated murder.

The central issue is whether the evidence supports a conviction for frustrated murder or if it only substantiates the crime of serious physical injuries.

Whether the defendant’s actions, including the method of attack and his motive driven by jealousy, sufficiently demonstrate an intention to kill Calderon.

Whether the circumstantial facts—such as the use of a deadly weapon, the location of the wound, and the element of treachery—justify inferring the necessary intent to effectuate death, notwithstanding the fact that the victim survived.

Whether the established legal doctrines on frustrated crimes and the inference of intention from surrounding circumstances apply adequately to the facts of the case.