People v. Lazada
REITERATIONFacts
The Antecedents: Agapito Lazada and Santiago Lazada were charged with inflicting serious physical injuries (lesiones graves) upon a Chinaman named Pedro Sopengco. The information alleged that the accused voluntarily, feloniously, and maliciously assaulted Sopengco with their fists, causing bruises to his eyes, mouth, and chest, which required more than thirty but less than ninety days to heal and prevented him from doing his habitual work. Procedural History: The trial court acquitted the accused of lesiones graves but found Agapito Lazada guilty of lesiones menos graves. The court determined that the injuries did not result in illness or disability for work exceeding thirty days but did require medical care and incapacitated the victim for work for more than seven days. Agapito Lazada was sentenced to four months of arresto mayor, a P50 indemnity, subsidiary imprisonment, and costs. He appealed this judgment. The Appeal: The appellant, Agapito Lazada, contended that the offense committed was a mere misdemeanor (falta) under Article 587 of the Penal Code, not lesiones graves or lesiones menos graves. He argued that if it were a misdemeanor, the action had already prescribed because the information was filed more than two months after the offense. The Supreme Court reviewed the evidence and testimony, noting that the incident arose from a dispute over a hen, and the appellant admitted the assault but claimed the injuries were trivial.
Issue(s)
Whether the offense committed was lesiones graves, lesiones menos graves, or a misdemeanor (falta). Whether the criminal action for the offense had prescribed.
Ruling
The Supreme Court reversed the judgment of conviction and sentence imposed by the trial court. It found the appellant guilty of the misdemeanor defined and penalized in Article 587 of the Penal Code and sentenced him to twenty-five days of arresto mayor, a P50 indemnity with subsidiary imprisonment, and costs.
Ratio Decidendi
On Issue 1: The Supreme Court found that the injuries inflicted upon Pedro Sopengco were not serious enough to constitute lesiones graves or lesiones menos graves as defined by the Penal Code. The Court considered the testimony and evidence presented, concluding that the injuries, while requiring medical attention and causing some incapacity for work, did not meet the threshold for the more serious offenses. Consequently, the Court classified the offense as a misdemeanor (falta) under Article 587 of the Penal Code, which covers physical injuries that prevent the injured person from working for one to seven days or require medical attendance for a like period. The penalty for such an offense is arresto menor. On Issue 2: The Supreme Court rejected the appellant's contention that the criminal action had prescribed. The Court noted that the complaining witness reported the incident to the justice of the peace on the day it occurred, and preliminary proceedings were conducted within sixty days of the offense. Under Article 131 of the Penal Code, the institution of criminal proceedings interrupts the prescriptive period. Therefore, the penal liability of the accused was not extinguished because the prescriptive period was interrupted by the commencement of these proceedings and suspended during their continuance.
Main Doctrine
The Supreme Court reiterated that the classification of physical injuries under the Penal Code depends on the duration of the injured party's incapacity for work and the necessity of medical attendance. It also affirmed that the institution of criminal proceedings, even preliminary ones, interrupts the prescriptive period for offenses, preventing the extinguishment of criminal liability.