Case Digest (G.R. No. 12066)
Facts:
The case of The United States vs. Angel Joven was initiated in the Court of First Instance of Pampanga on July 17, 1915, when the provincial fiscal filed a complaint against Angel Joven for the crime of attempted homicide. The incident occurred on June 13, 1915, in Bacolor, Pampanga, where the defendant, armed with a pocket-knife, assaulted his cousin, Edilberto Joven, inflicting multiple wounds. During the assault, Edilberto was crossing the street near the local market when he noticed Angel's pale appearance and inquired about his health. In response, Angel drew a pocket-knife from his pocket and attacked Edilberto, causing wounds to his neck, left forearm, and stomach. The attack was interrupted by Fortunato Datu, who intervened and restrained Angel, allowing Edilberto to escape to his pharmacy for medical assistance. Edilberto suffered significant injuries, requiring two operations and resulting in lasting impairment to his arm. The trial concluded on October 25, 19...
Case Digest (G.R. No. 12066)
Facts:
Incident Details:
- On June 13, 1915, in Bacolor, Pampanga, Angel Joven (defendant) assaulted his cousin, Edilberto Joven, with a pocket-knife.
- The assault occurred between 3 and 4 PM in front of the market.
- Edilberto Joven sustained multiple wounds: one on the neck, one on the left forearm, and one on the stomach.
- Fortunato Datu intervened, preventing further harm by holding the defendant's arm.
Medical Evidence:
- Dr. Clemente Punu testified that the neck wound was serious and could have been fatal if deeper, as it was near major arteries.
- The forearm wound was also potentially life-threatening if untreated.
- The stomach wound was less severe but could have been fatal if deeper.
- Edilberto Joven required hospitalization and two surgeries, leaving his left arm weakened and partially incapacitated.
Weapon Used:
- The weapon was an automatic pocket-knife with a five-inch blade, capable of causing significant harm.
Defendant's Intent:
- The defendant stated, "Until I can kill you," while pursuing Edilberto Joven.
- The nature and location of the wounds indicated an intent to kill.
Damages and Expenses:
- Edilberto Joven incurred approximately P400 in medical and travel expenses.
- Doctor Punu estimated his fees at P80-P100, which had not yet been collected.
Defendant's Defense:
- The defendant did not present evidence during the trial.
- On appeal, he argued that the crime should be classified as "lesiones menos graves" (less serious physical injuries) rather than attempted homicide.
- He also contested the indemnity of P500, claiming damages were not proven.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Intent to Kill:
- The defendant's intent to kill was established by his use of a deadly weapon, the nature and location of the wounds, and his statement during the assault.
- The intervention of a third party (Fortunato Datu) prevented the crime from being completed, making it an attempted homicide.
Indemnity for Damages:
- Under Article 122 of the Penal Code, courts are authorized to determine the amount of indemnity based on the nature and consequences of the injuries.
- The lower court's assessment of P500 was reasonable, considering the medical expenses, the victim's partial incapacitation, and the testimony of the victim and the attending physician.
Penalty Adjustment:
- The Supreme Court corrected the penalty imposed by the lower court, changing it from presidio correccional to prision correccional, as the latter was the appropriate penalty under the circumstances.