Case Summary (G.R. No. 39552)
Applicable Law
The legal provisions relevant to the case are found in the Revised Penal Code of the Philippines, specifically concerning frustrated murder and serious physical injuries.
Summary of the Facts
On the morning of November 23, 1932, Calderon was unexpectedly attacked by de la Cruz, who stabbed him in the back with a knife. Calderon, after being stabbed, rolled down the stairway and was subsequently treated for serious wounds which required prolonged medical attention, leading to incapacity for work and incurring significant medical expenses.
Procedural History
Upon being arraigned, de la Cruz pleaded not guilty. He opted to waive his right to present any evidence in his defense during the trial. The Court of First Instance of Nueva Ecija subsequently rendered a judgment convicting him of frustrated murder, sentencing him to twelve years and one day of reclusion temporal and ordering him to indemnify Calderon.
Issue on Appeal
The principal argument on appeal raised by the appellant was that the evidence presented did not sufficiently establish the intention to kill, contending that he should instead be convicted of serious physical injuries.
Inference of Intent to Kill
The court analyzed whether de la Cruz's actions constituted the crime of frustrated murder or merely serious physical injuries. The court held that the intent to kill could be inferred from several factors, including the circumstances surrounding the attack, the weapon used, and the nature of the inflicted wound. The prosecution successfully argued that de la Cruz's motives, stemming from jealousy regarding a relationship with Calderon, added context to his actions.
Essential Elements of Frustrated Murder
The court found that the crime committed involved the use of a deadly weapon against a vital area of Calderon’s body. Moreover, the treacherous manner of the attack—being executed from behind—resulted in Calderon being caught off guard, thus fulfilling the criteria necessary to classify the defendant's actions as those of frust
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Case Overview
- This case is an appeal from a judgment by the Court of First Instance of Nueva Ecija.
- The defendant-appellant, Lorenzo de la Cruz, was convicted of frustrated murder.
- The incident occurred on November 23, 1932, in Aliaga, Nueva Ecija, where Lorenzo de la Cruz stabbed Raymundo Calderon, the chief of police.
- The prosecution presented an information detailing the crime, including elements of treachery, evident premeditation, and intent to kill.
Facts of the Case
- On the morning of November 23, 1932, at approximately 8:30 a.m., Raymundo Calderon was attacked by Lorenzo de la Cruz while descending a stairway in the municipal building.
- Without any exchange of words, de la Cruz stabbed Calderon in the back with a knife.
- The attack resulted in Calderon rolling down the stairway, indicating the unexpected nature of the aggression.
- Following the stabbing, Calderon was taken to a dispensary and then to a hospital where he received medical treatment for serious wounds affecting his lung.
- Calderon was hospitalized from November 23 to December 24, 1932, incurring significant medical expenses and losing his salary durin