People v. Cruz
REITERATIONFacts
The Antecedents: On November 23, 1932, in the municipal building of Aliaga, Nueva Ecija, the defendant-appellant Lorenzo de la Cruz, with premeditation and intent to kill, attacked and stabbed Raymundo Calderon, the chief of police, with a knife. The stab wound was inflicted on the back as Calderon was descending the stairs. The aggression was unexpected and without prior exchange of words. Calderon sustained a serious wound that required medical attendance for more than 30 but less than 90 days and incapacitated him for labor for a like period. The wound affected the right lung, causing him to vomit blood and spit blood. He was hospitalized from November 23, 1932, to December 8, 1932, and later in Manila from December 9 to December 24, 1932. He resumed work on February 1, 1933, having lost earnings and incurred P800 for treatment. Procedural History: The Court of First Instance of Nueva Ecija convicted the defendant-appellant of frustrated murder. The defendant waived his right to present evidence. The lower court found that the defendant believed the victim had won the affection of his concubine, providing a motive for the attack. The court also considered the use of a deadly weapon, the infliction of the wound from behind (treachery), and the potential belief of the accused that he had inflicted a mortal wound. The Petition: The defendant-appellant appealed the judgment, arguing that the evidence was insufficient to establish intent to kill, and he should only be convicted of serious physical injuries.
Issue(s)
Whether the prosecution sufficiently established the element of "intent to kill" to sustain a conviction for frustrated murder rather than serious physical injuries.
Ruling
The Supreme Court affirmed the judgment of the lower court, finding the defendant-appellant guilty of frustrated murder.
Ratio Decidendi
On Issue 1: The Supreme Court held that intent to kill was sufficiently proven through circumstantial evidence. Applying the doctrine from U.S. v. Eduave, the Court emphasized that in the absence of an express declaration, intent must be inferred from the facts of the case. The Court identified four critical factors: First, the motive of the accused was the desire to keep his concubine and eliminate a perceived romantic rival. Second, the accused used a deadly weapon and targeted a vital area (the upper thorax/lung), which he could reasonably assume would be fatal. Third, the attack was executed with treachery from behind, catching the victim unaware and ensuring no risk to the assailant. Fourth, the fact that the victim collapsed and rolled down the stairs led the accused to reasonably believe he had already inflicted a mortal wound, which explains his lack of further pursuit. Because the accused performed all acts of execution and the victim only survived due to major surgery to remove bloody serum from the pleural cavity, the crime is properly classified as frustrated murder.
Main Doctrine
The intention to kill, in the absence of express declaration, may be inferred from the motive, the use of a deadly weapon, the infliction of a wound in a vital spot, the manner of attack (treachery), and the surrounding circumstances, all of which may lead to the reasonable belief that the accused intended to inflict a mortal wound.