Case Summary (G.R. No. 198010)
Judgment and Charges
The Court of First Instance of Iloilo convicted Pablo Villanueva of frustrated parricide, sentencing him to fourteen years, eight months, and one day of reclusion temporal and ordering him to pay legal costs. Villanueva appealed this judgment, contesting the conviction.
Incident Background
Prior to the incident on June 23, 1927, underlying tensions existed between Villanueva and Salvacion Tesoro. Evidence indicated that Villanueva had previously threatened his wife with a hatchet, claiming it was not for chopping wood but for use against her. On the day of the incident, after a verbal altercation between Salvacion and Villanueva’s younger sister, Villanueva intervened ominously, suggesting “lightning is going to strike soon, and there will be a cutting.”
The Assault
In a further escalation, Villanueva attacked Salvacion with a hatchet, striking her on the head and causing a non-life-threatening gash. When Salvacion attempted to defend herself, she fractured her wrist. Another woman, a sister-in-law of Villanueva, intervened, halting Villanueva’s aggression.
Medical Condition of the Injured Party
Salvacion's injuries required around fifteen days to heal, and she was incapacitated for approximately twenty-five days. Even during the trial, Salvacion reported ongoing pain in her wrist, illustrating the incident's substantial impact on her daily life.
Legal Assessment of the Offense
The court found that the injuries inflicted by Villanueva qualified as “lesiones menos graves” (minor physical injuries) under Article 418 of the Penal Code, citing that the injuries required more than eight but less than thirty days for recovery. The court recognized the aggravating circumstance of the marital relationship but noted that no mitigating circumstances existed, leading to a proposed penalty of six months of arresto mayor.
Reversal of Frustrated Parricide Conviction
The appellate court disagreed with the lower court's classification of the offense as frustrated parricide. The judges collectively determined there was insufficient evidence to demonstrate that Villanueva had a definitive intent to kill Salvacion, as the actions reflected bluster and intimidation rather than a premeditated desire to take life. The court emphasized that the intent to kill must be demonstrated beyond a reasonable doubt, particularly in serious offenses.
Arguments on Intent to Kill
It was noted that the mere act of using a weapon does not equate to intent to kill; the context and circumstances must be examined thoroughly. The court opined that Villanueva's aggressive behavior seemed more aligned with intimidation than with a serious intent to murder. Furthermore, external intervention led to the defendant's cessation of the assault, hence indicating that his desistance might not stem from remorse but from a reaction to external circumstances.
Final Ruling
The court reversed the conviction of frustrated parricide
...continue readingCase Syllabus (G.R. No. 198010)
Case Overview
- The case involves an appeal by Pablo Villanueva challenging a judgment from the Court of First Instance of Iloilo.
- The appellant was found guilty of frustrated parricide and sentenced to fourteen years, eight months, and one day of reclusion temporal, alongside the obligation to pay costs.
Background of the Case
- Pablo Villanueva and Salvacion Tesoro were married and lived in Balasan, Iloilo, until June 23, 1927.
- Prior to the incident, there existed notable animosity between the couple.
- Days before the offense, Villanueva threatened his wife by brandishing a hatchet, indicating it was not for wood but for her.
Incident Description
- On June 23, 1927, an altercation occurred between Salvacion Tesoro and Villanueva's younger sister, prompting Villanueva to intervene.
- He warned his sister to leave Tesoro alone, stating ominously that "lightning is going to strike soon, and there will be a cutting."
- Shortly after, Villanueva attacked Tesoro with a hatchet, striking her on the right side of the head, causing a non-dangerous wound.
- A second attack aimed at her was parried by Tesoro, resulting in a fractured wrist.
- A third blow was attempted but missed, with the hatchet striking her shoulder instead.
- The assault was ultimately stopped by another woman, the wife of Villanueva's b