Title
Abella y Perpetua vs. People
Case
G.R. No. 198400
Decision Date
Oct 7, 2013
Petitioner hacked brother with a scythe, causing severe neck injury; convicted of frustrated homicide; intent to kill inferred from weapon, wound location, and attack circumstances.

Case Summary (G.R. No. 198400)

Antecedent Facts

On the night of September 6, 1998, following a quarrel involving the petitioner, Benigno was attacked by Fe who wielded two scythes. The assault resulted in significant injuries to Benigno, particularly a hacking wound to his neck and an incised wound to his hand. Despite these injuries, Benigno survived due to timely medical intervention, albeit at a cost of over P10,000 for hospitalization, which he could not substantiate with receipts.

Defense Strategy

During the trial, the petitioner relied on the defenses of denial and alibi, claiming that he was not present at the crime scene during the relevant time. However, no disinterested witnesses corroborated his account, and the RTC found the defenses insufficient against the prosecution's evidence.

RTC Ruling

On July 13, 2006, the RTC convicted the petitioner of frustrated homicide, imposing an indeterminate sentence ranging from six years and one day to eight years of prision mayor. Additionally, the court ordered him to pay Benigno damages for medical expenses and consequential damages, despite a lack of concrete evidence supporting these claims.

CA Ruling

The CA upheld the RTC's conviction but modified the sentence to a range of six months and one day up to six years of prision correccional, as the CA clarified that the nature of the injury and the intent to kill must align with the penalties set forth in the Revised Penal Code. The CA also adjusted the damages awarded, eliminating the previous awards while providing P30,000 in moral damages and P10,000 in temperate damages.

Issue

The petitioner contested the lower courts' decisions, asserting that the evidence failed to establish intent to kill. He argued that the act of a single hacking blow was accidental and not indicative of a murderous intention.

Supreme Court's Analysis

Upon reviewing the petition, the Supreme Court determined that the issue raised was predominantly factual, falling outside the permissible scope of review under Rule 45 of the Rules of Court, which primarily deals with questions of law. The Court acquiesced to the lower courts' findings about the presence of intent to kill based on the manner of the attack and the injuries inflicted on the victim.

Judicial Conclusion

The Supreme Court affirmed the decision of the CA, finding no reversible error in the findings of fact pe

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