Gil Bilazon v. People

Summary

Petitioners Gil Bilazon and Nestor Belen were charged with Frustrated Homicide for allegedly assaulting Domingo Givera with pieces of wood, causing serious injuries including multiple fractures. The Regional Trial Court initially convicted them of Frustrated Homicide, but the Court of Appeals modified this to Serious Physical Injuries, finding that the prosecution failed to prove intent to kill and the mortal nature of the wounds. The Supreme Court affirmed the Court of Appeals decision, emphasizing that Frustrated Homicide requires proof that the victim would have died without timely medical intervention, which was not established through expert medical testimony. The Court also corrected the lower courts' failure to award damages by granting temperate damages of P4,000 and moral damages of P5,000, both with 6% annual interest. This case demonstrates the strict evidentiary requirements for proving intent to kill in criminal cases and the distinction between different degrees of physical injury crimes.