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ALFREDO DE GUZMAN v. PEOPLE

FACTS:

This case involves the conviction of the petitioner for frustrated homicide committed against Alexander Flojo. The incident occurred on December 24, 1997, when Alfredo De Guzman, the brother of the victim's landlady, hit Alexander on the nape while he was fetching water below his rented house. Alexander informed his landlady about the incident, and she apologized to him. After resting for two hours, Alexander went back downstairs to continue fetching water. Suddenly, Alfredo appeared and stabbed Alexander on his left face and chest.

Alexander's son-in-law, Cirilino Bantaya, saw him bleeding and immediately loaded him onto his motorcycle to bring him to the hospital. Alexander was treated at the Mandaluyong City Medical Center, where he stayed in the emergency room for about 30 to 40 minutes before being transferred to the second floor for a two-day confinement. He was then transferred to the Polymedic General Hospital for further examination.

The medical examination revealed that Alexander sustained two stab wounds, one on the left side of his face and the other on his upper left chest. The second wound penetrated his thoracic wall and left lung, which required the insertion of a thoracostomy tube to remove the blood. The treating physician testified that the second wound was fatal and could have caused Alexander's death without immediate medical intervention.

On the other hand, the petitioner denied stabbing Alexander. He claimed that the two of them got into a fistfight, during which he accidentally hit Alexander's back, causing him to insult him. The petitioner asserted that he only caused slight physical injuries to Alexander and that another person may have inflicted the stab wounds.

The Regional Trial Court (RTC) convicted the petitioner of frustrated homicide and sentenced him to imprisonment. The Court of Appeals (CA) affirmed the RTC's decision. The petitioner appealed to the Supreme Court, arguing that his guilt had not been proven beyond reasonable doubt and that intent to kill was not established.

The appeal was denied, and the petitioner's conviction for frustrated homicide was upheld. The Supreme Court examined the elements of the crime and concluded that intent to kill was present based on the nature and location of the wounds inflicted on the victim.

ISSUES:

  1. Whether intent to kill is an essential element in the crimes of frustrated or attempted homicide.

  2. Whether the presence of intent to kill was proven in this case.

  3. Whether the court has the authority and duty to correct a matter of law and justice even if the parties did not appeal the issue.

  4. Whether the trial and appellate courts should prescribe the correct penalties and determine the civil liability ex delicto of the accused.

RULING:

  1. Intent to kill is an essential element in the crimes of frustrated or attempted homicide. It is a specific intent that the State must allege in the information and prove by either direct or circumstantial evidence. Intent to kill is discerned by the courts through the acts and conduct of the accused at the time of the assault and immediately thereafter.

  2. In this case, both the trial and appellate courts agreed that intent to kill was present. The wounds sustained by the victim were not mere scuffmarks but were caused by the petitioner wielding and using a knife. The unprovoked attack with a knife and the nature of the wounds proved the presence of intent to kill. The petitioner's conviction for frustrated homicide was affirmed.

  3. The court has the authority and duty to correct a matter of law and justice even if the parties did not appeal the issue. The court is the final reviewing tribunal and can correct any matter of law and justice at any time.

  4. The trial and appellate courts should prescribe the correct penalties and determine the civil liability ex delicto of the accused. It is the duty of the courts to fully determine the rights and obligations of the litigants, and they should prescribe the legal penalties and determine the civil liability ex delicto unless the enforcement of the civil liability has been reserved or waived.

PRINCIPLES:

  • Intent to kill is an essential element in the crimes of frustrated or attempted homicide. It is discerned by the courts through the acts and conduct of the accused at the time of the assault and immediately thereafter.

  • The presence of intent to kill can be proven by considering factors such as the means used by the offender, the nature and location of the victim's wounds, the conduct of the offender before, during, or immediately after the assault, the circumstances of the crime, and the motives of the accused.

  • The testimony of a single but credible and trustworthy witness, especially the victim himself, can be sufficient to support a conviction. The direct and positive identification of the assailant by the victim is regarded with indubitable credibility.

  • An indeterminate sentence consists of a maximum term and a minimum term. The maximum term is the penalty properly imposed under the Revised Penal Code, while the minimum term is within the range of the penalty next lower than that prescribed for the offense committed. In the absence of aggravating or mitigating circumstances, the proper penalty is determined by considering the medium period of the penalty prescribed for the offense.

  • The civil liability imposed on the accused should be prescribed by the courts unless there is a reservation or waiver of the action to recover civil liability. The courts should determine the proper penalties and civil liability in accordance with the law, the Rules of Court, and relevant jurisprudence.

  • The court has the authority and duty to correct a matter of law and justice even if the parties did not appeal the issue.

  • The trial and appellate courts should prescribe the correct penalties and determine the civil liability ex delicto of the accused.