FACTS:

Juan Pilares (defendant-appellant) was accused of lesiones graves (serious physical injuries) against Severino Manzano. The information alleged that on June 5, 1908, Pilares assaulted, beat, and struck Manzano in his house, causing injuries including a left knee injury, chest contusions, internal organ injuries, fever, and spitting of blood, which required more than thirty days of medical attention and rendered Manzano unable to work until his death. The injuries resulted in damages of P481.10.

Pilares demurred to the complaint, arguing that it failed to specify the required effects of lesiones under the Penal Code, such as mutilation, imbecility, or perpetual inability to work. The trial court overruled the demurrer.

During the trial, Matea Lim Icoy (Manzano’s wife) and Trinidad Manzano (daughter) testified that Pilares repeatedly struck, kicked, and dragged Manzano. Lorenzo del Pilar corroborated that Pilares struck Manzano after Manzano made a disrespectful remark. Physicians testified that Manzano’s injuries required medical attention for over thirty days, and he was unable to work from the day he was injured until his death.

The trial court convicted Pilares and, in imposing the sentence, considered the mitigating circumstance of arrebato y obcecacion (passion and obfuscation).

ISSUE:

1. Was the information for lesiones graves sufficient despite the defendant’s demurrer regarding the description of the injuries’ effects?
2. Did the trial court err in appreciating the mitigating circumstance of arrebato y obcecacion?

RULING:

1. Yes, the information was sufficient. The Supreme Court held that the information asserted all the facts required for lesiones graves under Article 416, subdivision 4, of the Penal Code, which penalizes injuries occasioning “illness or disability for work lasting more than thirty days.” The information explicitly stated that the injuries “required more than thirty days to be cured with medical attention during all that time” and that by reason of these injuries, Manzano was unable to work up to the time of his death. The Court clarified that it is not necessary to allege both “illness” and “disability for work”; either one lasting more than thirty days is sufficient.

2. Yes, the trial court erred in considering arrebato y obcecacion. The Supreme Court found that Manzano’s alleged provocation (disrespectful remarks) was not sufficient to justify the accused’s repeated attacks and produce a state of passion or obfuscation. For this mitigating circumstance to exist, there must be facts proving provocation sufficient to produce such a condition of mind. The Court concluded that no such facts were sufficiently proven in this case.

Accordingly, the Supreme Court affirmed the conviction but modified the sentence. The defendant, Juan Pilares, was sentenced to one year and eight months of prision correccional, with the judgment being affirmed as modified.