People v. Amante
REITERATIONFacts
The Antecedents: The case arose from a dispute between tenants and landlords concerning the eviction of tenants for non-payment of rent at the Hacienda de San Pedro Tunasan. A day prior to the incident, tenants had prevented the sheriff from demolishing a house. On March 27, 1935, the provincial sheriff, accompanied by Constabulary soldiers and hacienda employees including the offended party, Anselmo Reyes, went to demolish Lucio Lizarda's house. They were met by approximately a thousand tenants. While the hacienda's assistant administrator, Policarpo Manas, was examining rental receipts with Lizarda, the appellant, Pedro Amante, shoved Manas. Amante then signaled his followers, leading to an attack on Manas and Reyes. Reyes was stabbed in the back by Amante and also wounded in the head by another assailant. Procedural History: The appellant was prosecuted and convicted of frustrated homicide by the Court of First Instance of Laguna, which imposed an indeterminate penalty. The sentence was affirmed by the Court of Appeals. The appellant then filed a petition for review with the Supreme Court. The Petition: The appellant, not being satisfied with the decision of the Court of Appeals, filed a petition for review. He acknowledged that the evidence could not be re-examined at this stage and that the facts established by the Court of Appeals were final. His sole argument was that the crime committed, based on the established facts, was not frustrated homicide but simple serious physical injuries (lesiones menos graves) punishable under Article 265, paragraph 1 of the Revised Penal Code.
Issue(s)
Whether the appellant is guilty of frustrated homicide or serious physical injuries. Whether the facts established by the Court of Appeals support a conviction for frustrated homicide.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of the appellant for frustrated homicide. The Court ordered the appellant to pay the costs of the proceedings.
Ratio Decidendi
On Issue 1: The Court held that the appellant was guilty of frustrated homicide. The established facts showed that the appellant shoved Policarpo Manas and then signaled his followers to commence hostilities against Manas and the offended party, Anselmo Reyes. The appellant himself stabbed Reyes in the back with a bolo, a deadly weapon, inflicting a serious wound that would have been fatal had it not struck a bone. Furthermore, Reyes was also wounded in the head by another assailant. The Court reasoned that the appellant performed all the acts of execution that should have resulted in homicide, but the crime was not consummated due to causes independent of his will, such as the victim's bone deflecting the blow. The use of a deadly weapon and the infliction of a wound on a vital part of the body, coupled with the evidence of preconcerted action among the appellant and his followers, clearly indicated the intent to kill. Therefore, the crime committed was frustrated homicide, not merely serious physical injuries. On Issue 2: The Court found that the facts declared proven by the Court of Appeals sufficiently supported the conclusion that the crime committed was frustrated homicide. The appellant's contention that the crime should only be considered serious physical injuries was rejected. The Court emphasized that it could not review the evidence or alter the facts as found by the appellate court. The facts, as narrated by the Court of Appeals, included the appellant's instigation of the attack, his act of stabbing the offended party in the back with a bolo, and the subsequent wounding of the victim in the head by one of the appellant's followers. These actions, particularly the stabbing in a vital part of the body with a deadly weapon, were deemed sufficient to establish the intent to kill and the commission of acts of execution for homicide, which, due to external causes, did not result in death. The Court concluded that the appellate court correctly applied the law to these established facts.
Main Doctrine
The Supreme Court affirmed the conviction for frustrated homicide, holding that the accused performed all the acts of execution that would have resulted in homicide, but the crime was not consummated due to circumstances beyond his control. The Court emphasized that the intent to kill could be inferred from the use of a deadly weapon (bolo) and the infliction of a serious wound on a vital part of the victim's body, compounded by the fact that the attack was part of a concerted action with his followers. The Court also noted that in a petition for review, the appellant is limited to discussing the conclusions of the appellate court and cannot seek a re-examination of the evidence or alteration of the established facts.