G.R. No. 243805 , September 16, 2020
Eduardo Lacson y Manalo, Petitioner, v. People of the Philippines, Respondent.

FACTS

Petitioner Eduardo Lacson, along with several co-accused (the Lacsons), was charged with six counts of Attempted Homicide. The Amended Informations alleged that on May 5, 2011, in San Fernando, Pampanga, the accused, conspiring and mutually helping each other, assaulted six members of the Santos family with a steel pipe with intent to kill. The commission was allegedly halted not by their desistance but by the timely intervention of other persons. After trial, the Municipal Trial Court in Cities (MTCC) convicted Eduardo of six counts of Less Serious Physical Injuries, a finding affirmed by the Regional Trial Court (RTC).
The Court of Appeals (CA) modified the trial courts’ rulings. It affirmed Eduardo’s conviction but only for four counts of Less Serious Physical Injuries, acquitting him for the injuries to two victims due to insufficient evidence of his direct participation in those specific assaults. The CA found that the prosecution failed to prove the element of intent to kill required for Attempted Homicide. It ruled that the injuries inflicted, which required medical treatment and incapacitated the victims for ten to thirty days, were properly classified as less serious physical injuries under Article 265 of the Revised Penal Code.

ISSUE

Whether the Court of Appeals correctly convicted petitioner Eduardo Lacson of four counts of Less Serious Physical Injuries instead of Attempted Homicide.

RULING

Yes, the Supreme Court affirmed the CA’s decision. The legal logic hinges on the distinction between the crimes of Attempted Homicide and Less Serious Physical Injuries, specifically the requisite proof of intent. For a conviction of Attempted Homicide, the prosecution must prove beyond reasonable doubt the accused’s specific intent to kill. This intent must be deducible from the totality of circumstances, such as the weapon used, the manner of attack, and the nature of the wounds inflicted.
The Court agreed with the CA that the evidence failed to establish such intent to kill. The use of a steel pipe and the resulting injuries, while causing harm, did not conclusively demonstrate a purpose to end the victims’ lives. The injuries were classified as less serious, healing within the periods specified under Article 265 of the RPC. Absent clear proof of intent to kill, the felony committed is properly the consummated crime of Less Serious Physical Injuries, not an attempted stage of a more serious crime. The Court also upheld the CA’s factual findings on the petitioner’s identifiable participation in the tumultuous affray against four specific victims, making him liable for their injuries. The penalties and damages imposed were sustained as proper and in accordance with law.