GR L 10615; (November, 1915) (Digest)
G.R. No. L-10615; November 16, 1915
THE UNITED STATES, plaintiff-appellee, vs. ALEJANDRO ZAMORA, defendant-appellant.
FACTS:
On the evening of December 8, 1914, in Sibulan, Oriental Negros, the defendant, Alejandro Zamora, had an altercation with his sweetheart, Francisca Fonollera. When she showed indifference, he attempted to slap her, caught her by the hair, and embraced her on the ground. The municipal president and others intervened, separating them. After freeing himself, Zamora ran to Fonollera’s house but did not find her. He then approached Custodio Pisan, who was chopping wood at the foot of his house’s stairs. Zamora sat beside Pisan, lamented his situation, and suddenly struck Pisan with a pocketknife, inflicting a severe abdominal wound. Pisan died two days later. Zamora fled but was promptly arrested by the chief of police, who confiscated the open pocketknife. At trial, Zamora claimed he acted unconsciously, unaware he was holding the knife, and had no intent to wound Pisan.
ISSUE:
Whether the defendant, Alejandro Zamora, is guilty of the crime of homicide.
RULING:
Yes, the defendant is guilty of homicide. The Supreme Court affirmed the judgment of the Court of First Instance, finding Zamora guilty as principal for the killing of Custodio Pisan.
The Court rejected Zamora’s defense that he acted unconsciously and without knowledge of holding the knife. His detailed recollection of the events leading to and following the stabbing contradicted his claim of unawareness. The act was deemed free, voluntary, and intentional. The Court applied Article 1, paragraph 3, of the Penal Code, which holds a person criminally liable for a voluntary felony even if the wrongful act differs from that intended. Although Zamora’s anger originated from the quarrel with his sweetheart, his criminal liability extends to harming Pisan, an innocent third party. No mitigating or aggravating circumstances attended the crime. The penalty imposed was reclusión temporal in its medium degree (15 years), with the corresponding accessory penalties, and an indemnity of P1,000 to the heirs of the deceased.
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