Title
Epifanio y Lazaro vs. People
Case
G.R. No. 157057
Decision Date
Jun 26, 2007
Petitioner stabbed victim, who survived due to timely aid; intent to kill proven, but crime classified as Attempted Murder due to interrupted execution.
A

Case Summary (G.R. No. 218406)

Petitioner

Leonidas Epifanio y Lazaro pleaded not guilty at arraignment and testified in his own defense, offering an alibi and a narrative that he assisted the injured Crisaldo after the attack and was later detained but released.

Respondent

People of the Philippines, represented by the Office of the Solicitor General (OSG) on appeal.

Key Dates

Relevant procedural and factual dates appearing in the record include: the incident (August 15, 1990); filing of the Information (January 4, 1991); arraignment (June 25, 1991); trial testimony dates; RTC decision (July 5, 1994); appellate disposition at the Court of Appeals and subsequent proceedings referenced in the record.

Applicable Law

The 1987 Constitution governs the case (decision date post-1990). Criminal statutes and rules applied include the Revised Penal Code provisions invoked in the Information (Article 248 as to murder/frustrated murder; Article 6), Article 51 (for attempted offenses), the Indeterminate Sentence Law for fixing minimum and maximum terms, and procedural rules including Rule 45 (Petition for Review on Certiorari).

Factual Background

On the evening of August 15, 1990, Crisaldo and his cousin Allan walked home along a narrow path. Crisaldo felt a piercing thrust in his back, turned, and saw petitioner. Petitioner stabbed Crisaldo again, hitting his left arm as Crisaldo defended himself. Allan, hearing Crisaldo’s outcry, rushed to his aid, called petitioner by name, and petitioner fled. Crisaldo was taken first-aid to a local hospital, then transferred to Davao Medical Center, where he recuperated for approximately three weeks.

Medical Evidence

An attending physician, Santiago Aquino, issued a medical certificate dated September 4, 1990, describing: a stab wound to the right scapular area (medial border) at the level of the 5th–7th intercostal spaces; a left arm medial aspect wound; fractures of the 7th and 8th ribs posteriorly on the right. The certificate estimated probable healing time of 15–30 days barring complication. No live testimony of the doctor regarding the mortal quality of the wounds was presented at trial.

Charges and Information

Petitioner was charged in the Information with Frustrated Murder, alleging treachery and evident premeditation, intent to kill, and that he performed “all the acts of execution which would produce the crime of murder” but that death did not occur due to timely medical assistance. The Information sought criminal penalties and damages for actual, moral, and compensatory harm.

Defense

Petitioner’s defense was principally denial with an alibi and an account that he had spent the day harvesting coconuts, returned home and slept, was awakened to help load the wounded Crisaldo into a jeep, and that he later was told he was a suspect and briefly detained. He asserted he did not commit the stabbing.

Trial Court Decision

The Regional Trial Court (Branch 4, Panabo, Davao) found petitioner guilty of Frustrated Murder and sentenced him to an indeterminate term of six years and one day to ten years of prision mayor, imposed accessory penalties, and ordered indemnity of P6,000.00 to the victim.

Court of Appeals Proceedings

Petitioner appealed to the Court of Appeals, which affirmed the RTC decision in toto. A Motion for Reconsideration before the CA was denied, and petitioner elevated the matter by a petition for review on certiorari under Rule 45.

Issue on Review

The sole issue presented in the petition was whether the guilt of the petitioner for the crime of Frustrated Murder was proven beyond reasonable doubt. Petitioner sought reclassification to the lesser offense of Attempted Murder, asserting absence of proof that the injuries were life-threatening and pointing to the medical certificate’s lack of an express finding that the wounds were mortal.

Prosecution’s Position on Appeal

The OSG argued that the failure to present the treating physician to testify on the wounds was not raised below but that appellate review could nonetheless consider such matters; that petitioner did not object to the admissibility of the medical certificate; that petitioner performed “all the acts of execution”; and that the victim’s three-week hospitalization is not determinative of whether injuries were fatal.

Reviewability and Scope of Appellate Examination

The Court recognized that an appeal in a criminal case opens the entire case for review, permitting correction of errors not assigned below. Hence the absence of doctor’s live testimony, while not objected to at trial, could be considered on appeal.

Legal Standard: Attempted vs. Frustrated Crime

The Court applied established distinctions: an attempted crime occurs when the offender is stopped prior to performing all acts which would produce the consummated crime (subjective phase not completed), whereas a frustrated crime exists when the offender has performed all acts of execution which should result in consummation, and failure to consummate is due to causes independent of the offender’s will. In homicide cases, a crucial consideration is whether the wound inflicted is mortal and would cause death absent medical intervention.

Proof of Intent to Kill

The Court found intent to kill established beyond reasonable doubt by Crisaldo’s consistent testimony describing the surprise attack from behind, the continuation of the assault when Crisaldo turned, and the treacherous manner of attack. The nature and manner of the assault supported a finding of specific intent.

Completion of Acts of Execution

Despite established intent, the Court concluded petitioner did not perform all acts of execution required for frustrated murder because Allan’s timely intervention caused petitioner to flee. Petitioner did not voluntarily desist; rather, external intervention prevented further assault. Therefore the subjective phase of the crime was not completed.

Importance of Medical Testimony on Fatality of Wounds

The Court emphasized that the prosecution failed to present testimonial evidence from the treating physician to demonstrate that the wounds were mortal in charact

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