People v. Dagman
REITERATIONFacts
The Antecedents: Elias Magbual, an employee of the hacienda "La Esperanza," was attacked by a crowd of approximately forty persons while performing his duties. The attack was motivated by prior dispossession of land by judicial order against individuals harboring enmity towards Magbual. The assault began with a shout of "Avance," and as Magbual attempted to escape, Anastasio Dagman struck him with a stone, causing him to fall. Luis Pacunla then wounded Magbual with a lance. Magbual's subsequent attempts to flee resulted in him falling again and sustaining wounds from bolos and clubs wielded by the accused. Magbual feigned death to escape further harm. Procedural History: Seven individuals, including Luis Pacunla, Andres Rebollido, Isabelo Rebollido, Juan Olanan, Anastasio Dagman, Valentin Tabladillo, and Luciano Pacunla, were charged with frustrated murder. The Court of First Instance of Nueva Ecija found each of them guilty of frustrated homicide and imposed sentences accordingly. The Petition: The defendants appealed the judgment, assigning two errors: (1) that the trial judge erred in finding that the accused had the intention to kill Elias Magbual, and (2) that the trial judge erred in finding an agreement to kill and sentencing all accused equally without considering individual participation.
Issue(s)
Whether the accused had the intention to kill Elias Magbual. Whether there was an agreement to kill Elias Magbual, justifying the equal sentencing of all accused. Whether the crime committed was frustrated homicide or frustrated murder.
Ruling
The Supreme Court modified the judgment of the lower court, classifying the crime as frustrated murder and sentencing each of the defendants and appellants to fourteen years, eight months, and one day of cadena temporal, with accessory penalties, and jointly and severally to reimburse the offended party P65 for medical services.
Ratio Decidendi
On Whether the accused had the intention to kill Elias Magbual: The Court affirmed the trial judge's finding that the accused had the intention to kill. This intent was evidenced by the circumstances surrounding the attack, including the nature of the wounds inflicted, the use of deadly weapons, the blows directed at vital parts of the body, and the aggressors' statements of their purpose to kill, such as "Vamos a matarle." The Court noted that the subjective phase of the crime was entirely passed, and subjectively, the crime was complete, as the assailants believed they had killed the victim. On Whether there was an agreement to kill Elias Magbual, justifying the equal sentencing of all accused: The Court found that the murderous intent and joint purpose of the accused were clearly demonstrated. The collective nature of the attack, involving a large crowd and coordinated actions, indicated a shared intent to cause Magbual's death. The trial judge's finding of guilt beyond a reasonable doubt for a crime included in the information was substantiated by ample proof, supporting the equal sentencing based on their proven joint purpose. On Whether the crime committed was frustrated homicide or frustrated murder: The Court, agreeing with the Attorney-General, classified the crime as frustrated murder. This classification was based on the presence of treachery (alevosia) as a qualifying circumstance, which ensured the assailants' safety while depriving the victim of the opportunity to defend himself. The felony was considered frustrated because the offenders performed all acts of execution necessary to consummate the crime, but it did not result in death due to causes independent of their will, specifically Magbual's feigning of death. The use of prohibited arms was also noted as an aggravating circumstance. The Court distinguished this from attempted murder, emphasizing that in frustrated murder, the accused believes they have completed all necessary acts to cause death, whereas in attempted murder, they desist before completion or are prevented from completing the acts.
Main Doctrine
The crime is frustrated murder when the offenders perform all the acts of execution which should precede the felony as a consequence but which do not produce it by reason of causes independent of the will of the perpetrators, coupled with the intent to kill and the presence of treachery.