People v. Mañaul
REITERATIONFacts
The Antecedents: The defendants, Apolonio Mañaul and others, were charged with the crime of lesiones graves for having cut off both ears of Placida Gonzalez on the evening of June 30, 1903. Procedural History: The judge below found the defendants guilty of the crime and sentenced them to six years' prision correccional, and costs. The judge considered the case as falling within article 416 of the Penal Code, imposing the penalty provided for in paragraph 2 of said article, due to the resulting deafness of the injured party. The penalty was imposed in its maximum degree, considering the aggravating circumstances of having been committed at night, through a promise, recompense, or reward, with the use of superior force, and at the house of the injured party. The Petition: The defendants appealed the judgment of the lower court.
Issue(s)
Whether the defendants are guilty of the crime of lesiones graves. Whether the aggravating circumstances considered by the trial court were correctly applied.
Ruling
The Supreme Court affirmed the judgment of the lower court with a modification regarding the aggravating circumstances. The conviction for lesiones graves was upheld. The penalty imposed was affirmed, with the modification that the aggravating circumstance of the crime being committed at the house of the injured party was not considered, as the defendants made the victim come out of her house to commit the crime. The defendants were credited with one-half of the time they had been in prison as detention prisoners.
Ratio Decidendi
On the guilt of the defendants for lesiones graves: The Court agreed with the findings of law and fact in the judgment below. The act of cutting off both ears of Placida Gonzalez clearly falls under the definition of lesiones graves as provided in the Penal Code. The resulting deafness of the injured party further supported the classification of the crime under article 416 of the Penal Code, specifically paragraph 2, which addresses acts causing deafness. The penalty imposed by the trial court was deemed appropriate for the gravity of the injury inflicted. On the aggravating circumstances: The Court agreed with the trial court's consideration of the aggravating circumstances of the crime having been committed at night, through a promise, recompense, or reward, and with the use of superior force. However, the Court disagreed with the finding that the crime was committed at the house of the injured party. The evidence clearly showed that the defendants compelled the victim to leave her house before the crime was consummated, thus negating this specific aggravating circumstance. Despite this modification, the overall penalty imposed was affirmed.
Main Doctrine
The Supreme Court affirmed the conviction for lesiones graves, modifying the aggravating circumstances considered by the trial court, and crediting the defendants with half the time of their detention.