People v. Reyes
REITERATIONFacts
The Antecedents: The defendant, Francisco Reyes, was charged with the crime of frustrated homicide. Procedural History: The court below found the defendant guilty of frustrated homicide and sentenced him to six years and one day imprisonment at hard labor, with costs. The Petition: The Attorney-General contended that the facts established by the record did not support a conviction for frustrated homicide but for 'lesiones menos graves' as provided in Article 418 of the Penal Code.
Issue(s)
Whether the acts committed by the defendant constitute frustrated homicide. Whether the acts committed by the defendant constitute 'lesiones menos graves'.
Ruling
The Supreme Court reversed the judgment of the court below. It ruled that the acts committed by the accused constitute the crime of 'lesiones menos graves' and sentenced the defendant to three months of 'arresto mayor', with deduction for time served as a detention prisoner. The defendant was also ordered to indemnify the offended party in the sum of 20 pesos, with subsidiary imprisonment in case of default, and to pay the costs of the instance.
Ratio Decidendi
On whether the acts constitute frustrated homicide: The Court held that the principal and most essential element of attempted or frustrated homicide is the intent on the part of the assailant to take the life of the person attacked. This intent must be proved in so clear and evident a manner as to exclude any doubt as to the real intention of the aggressor. In this case, there was nothing in the record which clearly and beyond doubt showed an intention on the part of the defendant to kill. Therefore, it would not be proper to classify the crime as frustrated homicide. On whether the acts constitute 'lesiones menos graves': The Court agreed with the Attorney-General's contention that the acts committed by the accused constitute the crime of 'lesiones' only. Given that the said 'lesiones' took more than eight days and less than thirty to cure, they should be classified as 'lesiones menos graves' in accordance with Article 418 of the Penal Code. The evidence clearly showed that the defendant was guilty of the assault. The Court imposed a penalty of three months of 'arresto mayor', ordered indemnity to the offended party, and awarded costs.
Main Doctrine
The crime of frustrated homicide requires proof beyond doubt of the intent to kill. In the absence of such clear intent, acts constituting assault that result in injuries requiring more than eight but less than thirty days to cure should be classified as 'lesiones menos graves' under Article 418 of the Penal Code.