In Philippine law, the distinction between attempted and frustrated murder hinges on whether the perpetrator has completed all acts of execution necessary to cause death, absent any external intervention. This case clarifies that even with evident intent to kill, if the accused is prevented from completing the act due to external factors, the crime is classified as attempted, not frustrated, murder. The Supreme Court emphasizes that the nature of the wounds inflicted must be proven fatal to elevate the charge to frustrated murder, underscoring the importance of medical evidence in establishing the severity of injuries.

When a Good Samaritan Alters the Course: Attempted Murder or Frustrated Intent?

The case of Leonidas Epifanio y Lazaro v. People of the Philippines revolves around an incident on August 15, 1990, when Crisaldo Alberto was stabbed in the back. Leonidas Epifanio (petitioner) was charged with frustrated murder, based on the claim that his actions would have resulted in Crisaldo’s death had it not been for timely medical intervention. The Regional Trial Court (RTC) convicted Epifanio of frustrated murder, a decision affirmed by the Court of Appeals (CA). However, the Supreme Court (SC) re-evaluated the case, leading to a crucial examination of the line between attempted and frustrated murder.

The central issue before the Supreme Court was whether the prosecution had successfully proven beyond reasonable doubt that the crime committed was indeed frustrated murder, or if it should be categorized as the lesser offense of attempted murder. The petitioner argued that there was a lack of substantial evidence to demonstrate that the injuries sustained by Crisaldo were life-threatening. He pointed out that the medical certificate provided a healing time of “15-30 days barring complication,” but failed to explicitly state that the wounds were inherently fatal. This argument challenged the assertion that all necessary acts of execution had been completed by the petitioner.

In its analysis, the Supreme Court referred to the landmark case of United States v. Eduave, which elucidates the difference between an attempted and a frustrated felony. According to this ruling, an attempted crime occurs when the offender is thwarted by an external force before completing all the acts that would lead to the consummated crime. In contrast, a frustrated crime is one where the offender performs all acts of execution necessary for the crime to occur, but it is not consummated due to reasons independent of the offender’s will. The determination hinges on whether the offender has passed the subjective phase of the crime, which includes the acts between the commencement of the crime and the point where the offender has done everything necessary to complete it.

The Court emphasized that in homicide cases, the infliction of a mortal wound—one that could cause death without medical intervention—is a key criterion for establishing frustrated homicide or murder. The intent to kill, a critical element, can be inferred from several factors, including the offender’s motive, the weapon used, the number and nature of wounds, the manner of the attack, and the offender’s utterances during the commission of the crime. In Epifanio’s case, the intent to kill was evident, as Crisaldo was stabbed from behind in a treacherous manner, and the assault continued until an external factor intervened.

However, the Supreme Court found that the prosecution failed to conclusively prove that Epifanio had performed all the acts of execution. Specifically, the intervention of Allan Perez, Crisaldo’s cousin, disrupted the assault. Furthermore, the prosecution did not provide adequate testimonial evidence regarding the nature of Crisaldo’s wounds. The Court referenced People v. Matyaong, which highlights the importance of assessing the extent of injury, the organs affected, and the potential danger to life. Without sufficient evidence demonstrating that the wounds were life-threatening in the absence of medical intervention, the Court was inclined to rule in favor of the accused.

“Where there is nothing in the evidence to show that the wound would be fatal if not medically attended to, the character of the wound is doubtful; hence, the doubt should be resolved in favor of the accused and the crime committed by him may be declared as attempted, not frustrated, murder.”

The Supreme Court therefore concluded that Epifanio was guilty only of attempted murder. The penalty for attempted murder, as per Article 51 of the Revised Penal Code, is prision correccional in its maximum period to prision mayor in its medium period. Applying the Indeterminate Sentence Law, the Court sentenced Epifanio to an indeterminate imprisonment of two years and four months of prision correccional, as minimum, and eight years of prision mayor, as maximum.

Regarding damages, the Court noted that while Crisaldo undoubtedly incurred expenses, the documented receipts amounted only to P853.50. Since the exact amount of expenses could not be definitively proven, the Court awarded temperate damages of P6,000.00, recognizing that Crisaldo did incur costs during his hospitalization. This decision highlights the importance of presenting comprehensive evidence to support claims for actual damages.

FAQs

What was the key issue in this case?	The key issue was whether the crime committed by Leonidas Epifanio was frustrated murder or attempted murder, based on the extent of the acts of execution and the nature of the injuries inflicted on the victim.
What is the difference between attempted and frustrated murder?	Attempted murder occurs when the offender does not complete all acts necessary for the victim’s death due to external intervention. Frustrated murder occurs when the offender completes all necessary acts, but the victim survives due to independent causes, like medical assistance.
What evidence is needed to prove frustrated murder?	To prove frustrated murder, the prosecution must demonstrate that the offender had the intent to kill and performed all acts of execution that would have resulted in the victim’s death without medical intervention. Medical evidence is crucial to establish the life-threatening nature of the wounds.
Why was the charge reduced to attempted murder in this case?	The charge was reduced because the prosecution failed to prove that the victim’s wounds were life-threatening absent medical intervention. Also, the accused was interrupted by a third party before he could complete the act.
What is the significance of the United States v. Eduave case?	The United States v. Eduave case provides the legal distinction between attempted and frustrated felonies, emphasizing the subjective and objective phases of a crime. It clarifies when an offender has completed all necessary acts for a crime to be considered frustrated.
What factors are considered to determine intent to kill?	Intent to kill can be determined from factors such as the offender’s motive, the type of weapon used, the number and nature of wounds inflicted, the manner of the attack, and any words spoken by the offender during the act.
What are temperate damages, and why were they awarded?	Temperate damages are awarded when actual damages are proven, but the exact amount cannot be determined. In this case, temperate damages were awarded to compensate for the expenses incurred during the victim’s hospitalization, even though the exact amount was not fully substantiated.
What was the final ruling of the Supreme Court?	The Supreme Court found Leonidas Epifanio guilty of attempted murder and sentenced him to an indeterminate imprisonment of two years and four months of prision correccional, as minimum, and eight years of prision mayor, as maximum. He was also ordered to pay P6,000.00 as temperate damages.

This case illustrates the critical importance of evidence in determining the severity of criminal charges. The Supreme Court’s decision underscores that intent alone is insufficient to establish frustrated murder; the prosecution must also prove that the actions taken would have resulted in death without external intervention. This ruling serves as a reminder of the nuanced legal standards required in criminal prosecutions and the significance of presenting comprehensive medical evidence.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: LEONIDAS EPIFANIO Y LAZARO, VS. PEOPLE, G.R. NO. 157057, June 26, 2007