G.R. No. 1017 - People vs. Villanueva

On the night of July 9, 1902, Juana Aguinaldo was ascending the stairway of her house in San Mateo, accompanied by her husband, Guillermo Yillanueva.
Yillanueva, acting as a police officer and carrying a revolver in his belt, was driven by an overwhelming passion of jealousy.

While following his wife, Yillanueva fired his revolver at her from approximately three yards away.
The bullet struck Juana in the back and traversed her body, entering between the sixth and seventh ribs on the right side near the omoplate and lung, and exiting near the nipple of the right breast.
The wound, though severe and potentially mortal, did not cause an immediate death; on August 7, clinical evidence showed she was still alive and gradually healing.

Prior to the shooting, Yillanueva suspected his wife of infidelity based on information that led him to the house of Captain Lucas.
After being told by Lucas’ wife that Juana was not present, Yillanueva later saw her emerge from the house.
His observations and prior information reinforced his suspicions, prompting him to take her back home.
At home, upon noticing evidence (clothes being packed by Pilar Pineda, presumed to belong to his wife) that supported his suspicions, he was further inflamed by jealousy.

Yillanueva’s actions, including the use of a deadly weapon and his deliberate aim at a critical body area, fulfilled all necessary elements that ordinarily lead to a violent death.
Despite the victim’s survival and gradual recovery, these were attributed to independent factors such as prompt and effective medical attention, not a lacking in his criminal intent.
The facts were deemed to constitute the crime of frustrated parricide as defined and punished by article 402 in connection with articles 3 and 407 of the Penal Code.

Whether Yillanueva’s act of firing at his wife, including the manner in which the bullet struck her, was performed with the direct intention to kill.
Whether the factors that led to the victim’s survival (such as the timely medical intervention) could exonerate him of his intentional criminal act.

Whether the crime should be classified as frustrated parricide, given the complete set of acts leading towards causing death.
How the nature and seriousness of the offense are affected by the survival of the victim.

The impact of the mitigating circumstance of acting under the impulse of passion (jealousy) on Yillanueva’s criminal liability.
The role of the aggravating circumstance of treachery (alevosia) in enhancing the gravity of the offense.