Case Summary (G.R. No. 28201)

Legal Standards for Intent in Homicide Cases

• Conviction for frustrated or attempted homicide requires proof of the intention to kill.
• The intention must be established with the same certainty as other elements of the offense.
• Inferences regarding intent should not be drawn without sufficient circumstantial evidence proving it beyond a reasonable doubt.

Presumption of Intent in Violent Acts

• The law presumes that individuals intend the natural consequences of their actions.
• This presumption must be applied rationally, considering all details of the act.
• A person is assumed to have intended to do what they actually did, not something more severe.

Case Background and Incident Description

• Pablo Villanueva was convicted of frustrated parricide for attacking his wife, Salvacion Tesoro.
• Prior to the incident, there was a history of marital discord, including threats made by Villanueva.
• On the day of the attack, Villanueva struck Tesoro with a hatchet, causing a non-life-threatening injury.

Nature of the Injuries and Legal Classification

• The injuries inflicted on Tesoro required more than eight but less than thirty days for healing.
• The court determined that the appropriate charge was minor physical injuries (lesiones menos graves) under Article 418 of the Penal Code.
• The relationship between the accused and the victim was considered an aggravating factor.

Assessment of Intent to Kill

• The court found insufficient evidence to support the claim that Villanueva intended to kill his wife.
• The actions of Villanueva were interpreted as bluster rather than a genuine intent to kill.
• The court emphasized that the intention to kill must be proven with convincing evidence incompatible with any other intention.

Rejection of Attempted Homicide Conviction

• The court ruled that the evidence did not support a conviction for attempted parricide.
• The intervention of a sister-in-law was deemed insufficient to establish that Villanueva's desistance was not voluntary.
• The court concluded that Villanueva's actions did not demonstrate a clear intent to kill.

Final Judgment and Sentencing

• The conviction for frustrated parricide was reversed.
• Villanueva was convicted of minor physical injuries and sentenced to six months of arresto mayor.
• The court ordered him to pay the costs o...continue reading