Case Summary (G.R. No. 1017)
Facts of the Case
On the night of July 9, 1902, Villanueva shot Aguinaldo with a revolver at a close range of approximately three yards while she was ascending the stairs of their residence. The bullet penetrated her back and exited near her breast. Although the wound was serious and potentially lethal, Aguinaldo survived and was reported to be healing by August 7, 1902.
Crime Classification
The acts committed by Villanueva constituted the crime of frustrated parricide, as defined under the relevant penal code articles. The evidence demonstrated that Villanueva intended to kill Aguinaldo, as he used a deadly weapon and aimed at a critical part of her body. The fact that she did not die was due to fortuitous circumstances and not to any action on Villanueva's part.
Defendant’s Defense
During arraignment, Villanueva admitted to the act but disclaimed criminal intent, claiming that his jealousy, stirred by suspicions of infidelity, prompted his actions. He asserted that upon confronting his wife and observing her actions post-encounter with another individual, he lost control and shot her.
Intent and Circumstances
The court found that Villanueva's act of shooting Aguinaldo was intentional, as there was no reasonable evidence suggesting it was a non-volitional act. Although he experienced a state of passionate jealousy, the ruling clarified that such emotional turmoil does not absolve him of criminal responsibility.
Mitigating and Aggravating Circumstances
The ruling acknowledged mitigating circumstance No. 7 of Article 9 of the Penal Code, regarding action fueled by passion; however, it also recognized the aggravating circumstance of treachery (alevosia) as outlined in Article 10. The perpetrator's calculated approach to the act contributed to the classification of the offense as a serious crime, thus elevating its gravity.
Penalty Imposed
Considering the entirety of the circumstances, the court decided to impose a penalty one degree lower than that prescribed for cadena temporal, leading to a sentence of eight years and one day o
...continue readingCase Syllabus (G.R. No. 1017)
Case Background
- The incident occurred on the night of July 9, 1902, in San Mateo, where Guillermo Villanueva shot his wife, Juana Aguinaldo.
- Villanueva was a member of the police force and used his service revolver to commit the act.
- The shooting took place from a distance of approximately three yards, hitting Aguinaldo in the back between the sixth and seventh ribs.
- The bullet traversed through her body, exiting near the right breast, and the seriousness of the wound was confirmed by a physician who stated it could have been mortal.
- Despite the severity of the injury, Aguinaldo was reported to be alive and healing as of August 7, 1902.
Legal Definition of the Crime
- The case was classified as one of frustrated parricide as defined under Article 402 of the Penal Code.
- The act of shooting was deemed intentional, as Villanueva performed all necessary actions that would typically result in the death of the victim.
- The fact that Aguinaldo survived was attributed to medical intervention rather than any lack of intent on Villanueva's part.
Defendant's Defense
- Villanueva admitted to the act but claimed he did not believe it constituted a crime.
- He cited jealousy over suspicions of his wife’s infidelity as the motive for his actions.
- His je