People v. Reyes
REITERATIONFacts
The Antecedents: The accused, Vicente Reyes, killed Guiseppe Goggiano, a soldier in the United States Army, during a quarrel over a game of cards. Reyes used a baston (stick) to strike the soldier on the head. Procedural History: The trial court found the defendant guilty of homicide, ruling that he did not act in self-defense and that no aggravating or mitigating circumstances existed. The court sentenced Reyes to fourteen years, eight months, and one day of reclusion temporal, with accessory penalties, indemnity to the heirs of the deceased, and costs. The Petition: The appellant's sole assignment of error was that the trial court erred in not finding the mitigating circumstance No. 3 of Article 9 of the Penal Code in his favor, specifically, that he had no intention to cause so great a wrong as that committed.
Issue(s)
Whether the mitigating circumstance of lack of intent to commit so grave a wrong (Article 9, No. 3 of the Penal Code) is applicable when the accused uses a stick to strike a vital part of the victim's body.
Ruling
The Supreme Court affirmed the decision of the trial court, holding that the mitigating circumstance No. 3 of Article 9 of the Penal Code was not applicable. The judgment of the trial court was affirmed with costs against the appellant.
Ratio Decidendi
On Issue 1: The Supreme Court held that the mitigating circumstance of lack of intent to commit so grave a wrong cannot be legally applied because there was no disproportion between the means employed and the evil produced. Applying various precedents from the Supreme Court of Spain, the Court reasoned that the intention of the agent is an internal act that can only be revealed through external and overt acts. In this case, the use of a 'baston' with enough force to fracture the cranium and cause death shows that the means were adequate and proportionate to the result. The Court emphasized that when a blow is directed at a vital part of the body, such as the head, using a powerful implement, it cannot be presumed that the offender intended to limit the consequences of his act. Therefore, the lack of intention to cause so serious an evil can only be considered in the absence of facts showing a notable disproportion between the means and the consequence. Since the injury caused corresponded with the efficacy of the implement used, the trial court correctly refused to apply the mitigating circumstance.
Main Doctrine
The intention of the offender is judged by the means employed and the resulting harm, and mitigating circumstance No. 3 of Article 9 of the Penal Code (lack of intention to cause so great a wrong as that committed) cannot be considered when the means used are adequate and proportionate to the result, or when there is no notable and evident disproportion between the means employed and the consequence.