Title
People vs Manlalang
Case
G.R. No. 2642
Decision Date
Aug 1, 1906
Defendant inflicted non-fatal wounds on victim with a pocketknife during a sudden, unprovoked assault. Supreme Court ruled the act as physical injuries, not attempted homicide, due to lack of intent to kill, but found treachery as an aggravating factor.

Case Summary (G.R. No. 2642)

Summary of the Incident

The defendant inflicted two knife wounds on Severa Villanueva, located on the upper right arm and left side of her body. Although the wounds were long, they were shallow and took thirteen days to heal. The attack was sudden and unexpected, leaving the victim no opportunity to defend herself. Notably, Severa was unarmed during the encounter.

Court's Initial Findings

The trial court classified the defendant's actions as attempted homicide and sentenced her to two years of hard labor along with the costs of the proceedings. The court based its judgment on the interpretation of the defendant’s actions as being indicative of an intention to kill.

Legal Analysis of Intent

The review of the case revealed that for an act to be classified as attempted homicide, a crucial element is the intent to kill. The circumstances surrounding the assault did not convincingly indicate that the defendant possessed such intent. The weapon used, the nature of the inflicted wounds, and the absence of a motive for killing Severa were essential factors that led to a reassessment of the case.

Conclusion on the Nature of the Crime

Given the evidence, it was concluded that the defendant did not intend to kill Severa but merely aimed to inflict harm. The defendant’s behavior after the assault — discarding the knife and not pursuing further violence — further supported this conclusion. Consequently, the crime was reclassified from attempted homicide to lesiones (personal injuries).

Sentencing and Penalties

As the wounds had healed within thirteen days, they qualified under the category of menos graves (less grave) injuries. Under Article 418 of the Penal Code, the appropriate penalties were determined to be either "arresto mayor," banishment, or a fine ranging from 325 to 3,250 pesetas, with the discretion of the court to decide specifics.

Aggravating Circumstances

The court acknowledged the presence of treachery, characterized by the unexpected nature of the assault, which impeded any chance for the victim to defend herself. This f

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