GR L 6782; (October, 1911) (Digest)
G.R. No. L-6782, October 24, 1911
THE UNITED STATES vs. PEDRO SANCHEZ
FACTS
The defendant, Pedro Sanchez, was charged with frustrated murder. In the early morning of March 31, 1910, in Binalonan, Pangasinan, Sanchez, armed with a sharp-pointed bolo, climbed a bamboo ladder to the window of the room where Walter P. Linton and his wife Nina were sleeping. He stabbed both victims while they were asleep, inflicting serious wounds. Walter Linton suffered a deep wound near his left armpit, and Nina Linton sustained a wound through her left arm and a superficial wound on her left side. Both survived after more than thirty days of medical treatment. Sanchez had previously been a servant in the Linton household and was familiar with the house layout. He had sought to return to their service just before the incident but was refused. The trial court convicted him of frustrated double murder, considering the qualifying circumstance of treachery and the aggravating circumstances of escalamiento (scaling) and unlawful entry into the victims’ dwelling.
ISSUE
Whether the crime committed should be classified as frustrated murder or merely lesiones menos graves (less serious physical injuries).
RULING
The Supreme Court affirmed the trial court’s judgment, classifying the crime as frustrated double murder. The Court held that the circumstances clearly demonstrated an intent to kill, supported by the treacherous manner of the attack. Sanchez assaulted the victims while they were asleep, ensuring his own safety and depriving them of any chance to defend themselves. The nature of the wounds, the deadly weapon used, and Sanchez’s prior knowledge of the house all indicated a determined intent to kill. The Court cited precedents from the Spanish Supreme Court where similar attacks from behind or on unsuspecting victims were classified as frustrated murder due to treachery. The presence of treachery (alevosia) justified the classification as frustrated murder, not merely physical injuries. The penalty imposed by the trial court was upheld.
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