People v. Pacis
REITERATIONFacts
The Antecedents: On January 15, 1925, an information was filed accusing Esteban Pacis of frustrated murder. The information alleged that on or about February 6, 1922, in the municipality of Bucay, Province of Abra, the accused, with intent to kill and with treachery, assaulted Fernando Bobiles while the latter was asleep in his home. The accused struck Bobiles with a bolo, inflicting serious wounds. The crime was not consummated due to timely and able medical assistance. The aggravating circumstances of treachery, nocturnity, and employment of means to insure immunity were alleged. Procedural History: The trial court found the defendant guilty of frustrated murder and sentenced him to fourteen years, eight months, and one day of imprisonment, with the accessories of the law, and to pay the costs. The Petition: The defendant appealed, contending that the trial court erred in designating the crime as frustrated murder, in finding him guilty of that crime, and in not acquitting him.
Issue(s)
Whether the crime committed was frustrated murder. Whether the defendant was guilty of frustrated murder.
Ruling
The Supreme Court affirmed the judgment of the lower court, holding that the crime committed was frustrated murder and that the defendant was guilty thereof. The judgment of the lower court is affirmed, with costs.
Ratio Decidendi
On whether the crime committed was frustrated murder: The Court held that the crime was indeed frustrated murder. The offended party, Fernando Bobiles, was asleep in his home and defenseless when he was attacked around midnight. The accused inflicted six serious wounds with a bolo, demonstrating a clear intent to kill. The wounds were described as serious, with one requiring sixty-three days to cure, another fifty days, one twenty-five days, one fifteen days, and a critical wound on the left wrist affecting the cubital artery and bones, curable in fifty-four days, and a final wound below the right shoulder causing permanent disability. The Court emphasized that the crime was not consummated due to causes independent of the accused's will, specifically the timely and able medical assistance rendered to the victim, which prevented his death. The presence of treachery, nocturnity, and the use of means to insure immunity further supported the classification of the crime as frustrated murder. On whether the defendant was guilty of frustrated murder: The Court found the evidence conclusive that the defendant committed the crime. The nature and number of wounds inflicted upon Fernando Bobiles indicated a vicious and brutal assault with the intent to kill. The Court distinguished the present case from People vs. Yabot, where the evidence was insufficient to sustain frustrated murder or homicide because the accused was not prevented from killing the victim. In contrast, the instant case involved a surprise attack on a sleeping and defenseless victim, with wounds that would have been fatal without medical intervention. The Court cited United States vs. Sanchez as analogous, where a conviction for frustrated murder was upheld based on similar circumstances of a surprise attack on sleeping victims with deadly weapons, coupled with aggravating circumstances that insured the assailant's safety. Therefore, the defendant was found guilty of frustrated murder.
Main Doctrine
The crime of frustrated murder is committed when all the acts of execution which should produce murder as a consequence are performed, but which nevertheless do not produce it by reason of causes independent of the will of the perpetrator, such as timely medical assistance. The presence of treachery, nocturnity, and the employment of means to insure immunity, coupled with the infliction of serious wounds upon a sleeping victim, clearly indicates the intent to kill, thus qualifying the offense as frustrated murder.