People v. Redion
REITERATIONFacts
The Antecedents: On November 16, 1903, in the city of Manila, Anastacio Redion inflicted a wound on Gertrudis Sanchez by cutting her in the face with a knife. The wound healed in fifteen days but permanently scarred and disfigured the victim's face. Procedural History: The Court of First Instance of Manila found Anastacio Redion guilty of frustrated homicide and sentenced him to two years' imprisonment and to pay the costs of the trial. The Appeal: Anastacio Redion appealed the decision of the Court of First Instance, arguing that he should not be convicted of frustrated homicide. The defense also contended that the victim, Gertrudis Sanchez, was the wife of the accused and that he had discovered her in flagrante delicto.
Issue(s)
Whether the accused is guilty of frustrated homicide. Whether the accused is guilty of physical injuries.
Ruling
The Supreme Court reversed the conviction for frustrated homicide and found the accused guilty of the crime of 'lesiones' (physical injuries) as defined and penalized in paragraph 3, article 416 of the Penal Code. The accused was sentenced to two years' prision correccional, to the accessory penalties prescribed by law, and to pay the costs in both instances.
Ratio Decidendi
On Issue 1: The Court held that the accused was not guilty of frustrated homicide because it was not proven beyond a reasonable doubt that he intended to kill Gertrudis Sanchez. While the accused inflicted a wound on the victim's face with a knife, the Court considered all the circumstances and concluded that the intention was not to kill. The permanent scarring, though a serious consequence, did not, in itself, establish the intent to commit the crime of homicide. Therefore, the elements of frustrated homicide, particularly the intent to kill, were not sufficiently established by the prosecution. On Issue 2: The Court found the accused guilty of the crime of 'lesiones' (physical injuries) under paragraph 3, article 416 of the Penal Code. This conclusion was based on the fact that the wound inflicted, although not intended to be fatal, resulted in permanent scarring and disfigurement of the victim's face. The Court also clarified that the provisions of article 423 of the Penal Code were not applicable, as it was not proven that Gertrudis Sanchez was the wife of the accused nor that he had discovered her in flagrante delicto. The crime of 'lesiones' was deemed necessarily included in the offense of frustrated homicide with which the accused was originally charged.
Main Doctrine
The Supreme Court reiterated that for a conviction of frustrated homicide, the prosecution must establish the offender's intent to kill. In this case, despite the infliction of a wound that permanently scarred the victim, the Court found that the evidence did not prove beyond reasonable doubt that the accused intended to kill the victim, thus reversing the conviction for frustrated homicide and convicting the accused instead for the crime of 'lesiones' (physical injuries).