Case Summary (G.R. No. 157057)
Background and Incident
On the evening of the incident, Crisaldo and his cousin, Allan Perez, were walking home after visiting Crisaldo's father. At approximately 9:00 PM, Crisaldo was attacked from behind and stabbed by the petitioner, resulting in injuries requiring hospitalization for three weeks. The stabbing caused a significant wound that, according to the medical certificate issued by Dr. Santiago Aquino, encompassed a stab wound in the right scapular area and a fractured rib. Legal charges were filed against the petitioner for Frustrated Murder due to the severe nature of Crisaldo's injuries, which, it was contended, could have been fatal without timely medical intervention.
Legal Proceedings
The petitioner was arraigned on June 25, 1991, pleading not guilty. His defense was primarily based on denial and an alibi claiming he was away harvesting coconuts during the time of the incident. After a trial, the Regional Trial Court (RTC) found him guilty of Frustrated Murder on July 5, 1994, sentencing him to an indeterminate imprisonment and ordering him to pay damages to the victim. The petitioner appealed, and the Court of Appeals (CA) upheld the RTC's decision.
Issues Raised on Appeal
The primary issue raised by the petitioner in his appeal was whether his guilt for Frustrated Murder was proven beyond a reasonable doubt. He argued that the prosecution failed to establish that the injuries inflicted on Crisaldo were life-threatening and therefore, his conviction should be reduced to that of Attempted Murder.
Legal Standards and Definitions
The distinction between Frustrated Murder and Attempted Murder comes down to the actions taken by the assailant in relation to the crime's completion. The legal framework necessitates that for Frustrated Murder, the offender must perform all acts necessary to consummate the crime, while Attempted Murder involves acts that do not reach that critical threshold of execution. In evaluating these phases, precedents such as United States v. Eduave clarify that the nature of the crime is determined not solely by the severity of the injuries but by the assailant achieving the subjective phase of the crime's execution.
Findings on Intent
The court found that the petitioner's intent to kill was established through Crisaldo's credible testimony regarding the attack and the surrounding circumstances, including the manner in which the assault was made. However, the court noted that the intervention of Allan Perez during the act of aggression prevented the petitioner from completing the execution of the crime.
Medical Evidence and its Implications
A critical element of the court's decision was the lack of testimony from the medical practitioner rega
...continue readingCase Syllabus (G.R. No. 157057)
Background of the Case
- The case revolves around a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court.
- The case was filed against the Decision dated May 22, 2002, of the Court of Appeals (CA) in CA-G.R. CR No. 17995.
- The CA affirmed the July 5, 1994 Decision of the Regional Trial Court (RTC), Branch 4, Panabo, Davao, which found Leonidas Epifanio y Lazaro (petitioner) guilty of Frustrated Murder.
- The CA Resolution dated January 14, 2003, subsequently denied the petitioner's Motion for Reconsideration.
Factual Background
- On the evening of August 15, 1990, Crisaldo Alberto and his cousin, Allan Perez, were walking home after visiting Crisaldo's father.
- While walking on a narrow pathway, Crisaldo was attacked from behind by the petitioner, who stabbed him with a bladed weapon.
- The first stab struck Crisaldo in the back, causing him to cry out, followed by a second stab that hit his left arm.
- Allan rushed to Crisaldo's aid, prompting the petitioner to flee the scene.
- Crisaldo received first aid at PeAaplata Hospital and was later transferred to Davao Medical Center, where he stayed for three weeks due to his injuries.
Medical Findings and Charges
- Dr. Santiago Aquino issued a Medical Certificate detailing Crisaldo's injuries, including a stab wound to the scapular area and fractures in his ribs.
- The petitioner was charged with Frustrated Murder in Criminal Case No. 91-15, with allegations of treachery and evident premeditation.