People v. Guillermo
REITERATIONFacts
The Antecedents: The accused attacked the victim with a pocket knife, inflicting a wound in the left hypochondrium. The victim died on the fourth day following the assault. The assault and its results were testified to by two eyewitnesses, corroborated by the deceased's statements to his wife and attending physician. The physician confirmed the wound was mortal. The fact of the deceased's death was also testified to by the same witnesses and the accused. Procedural History: The Court of First Instance imposed a sentence of twelve years and one day of reclusion temporal and ordered the defendant to pay an indemnity of 1,000 pesos to the heirs of the deceased. The Petition: The defendant appealed the decision of the Court of First Instance.
Issue(s)
Whether the accused is guilty of homicide. Whether the mitigating circumstance of intoxication should be considered.
Ruling
The judgment of the Court of First Instance is affirmed, with the addition of sentencing the defendant to pay the indemnity of 1,000 pesos to the heirs of the deceased. The costs of the instance are imposed upon the defendant.
Ratio Decidendi
On the issue of guilt for homicide: The act charged constitutes the crime of homicide, as defined and punished by Article 404 of the Penal Code. The evidence presented, including the testimony of two eyewitnesses and the statements of the deceased to his wife and physician, clearly established that the accused attacked the victim with a pocket knife, causing a mortal wound that led to his death. The physician's testimony confirmed the lethality of the wound, and the fact of death was corroborated by multiple witnesses, including the accused himself. Therefore, the elements of homicide were sufficiently proven beyond reasonable doubt. On the consideration of intoxication as a mitigating circumstance: The Court considered mitigating circumstance 6 of Article 9 of the Penal Code in favor of the defendant. The evidence sufficiently proved that the accused committed the act while in an intoxicated condition. Crucially, this intoxication was not habitual, which is a requirement for it to be considered a mitigating circumstance under the said provision. The presence of this mitigating circumstance, while not negating guilt, warrants a consideration in the imposition of the penalty, leading to the sentence imposed by the lower court being in accordance with the law.
Main Doctrine
The commission of a crime while in a state of intoxication, not habitual, is a mitigating circumstance under Article 404 of the Penal Code, reducing the penalty for homicide.