G.R. No. L-9291; March 2, 1914
THE UNITED STATES, plaintiff-appellee, vs. CAMILA CUNANAN, defendant-appellant.

FACTS:
Camila Cunanan was charged with and convicted of the crime of frustrated parricide by the Court of First Instance of Tarlac. The trial court sentenced her to fifteen years imprisonment, indemnification of the injured party, and payment of costs. The information specifically alleged that the crime was committed with treachery. The defendant appealed the judgment.

ISSUE:
Whether the penalty imposed by the trial court was correct in light of the presence of treachery as a generic aggravating circumstance and the absence of any extenuating circumstances.

RULING:
The Supreme Court affirmed the conviction but modified the penalty. The Court held that the evidence established the appellant’s guilt beyond reasonable doubt. However, it ruled that treachery is not an element of the crime of frustrated parricide and must therefore be considered as a generic aggravating circumstance. Since no extenuating circumstances were present, the minimum degree of the penalty prescribed by law must be imposed in accordance with Articles 65 and 95 of the Penal Code. Consequently, the judgment was modified. The appellant was sentenced to seventeen years, four months, and one day of reclusion temporal, with the corresponding accessory penalties. The order for indemnification and payment of costs was affirmed.