Title
People vs. Eduave
Case
G.R. No. 12155
Decision Date
Feb 2, 1917
Accused attacked a girl with a bolo, intending to kill her after she accused him of rape. Supreme Court ruled it as frustrated murder due to treachery, as he completed all acts necessary for the crime.

Case Digest (G.R. No. 12155)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Plaintiff-Appellee: The United States of America.
    • Defendant-Appellant: Protacio Eduave, who lived as the “querido” of the victim’s mother and was accused by the victim of rape and of causing her pregnancy.
  • Circumstances of the Offense
    • The accused armed himself with a sharp bolo and, without warning, rushed upon the girl from behind.
    • He struck her in the lumbar region and side, inflicting a gash eight and one-half inches long and two inches deep, severing all muscles and tissues in that area.
    • At the time of surrender, he declared that he intended to kill the girl, believed he had done so, and had thrown her body into the bushes.

Issues:

  • If death had resulted, would the crime have been murder or simple homicide?
  • Given that the victim survived, should the offense be classified as frustrated or attempted murder?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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