GR L 5319; (February, 1910) (Digest)
G.R. No. L-5319
THE UNITED STATES, plaintiff-appellee, vs. SABAS BAOIT, defendant-appellee.
February 26, 1910
FACTS:
Sabas Baoit (defendant) inflicted several lance wounds upon Wenceslao Agcaoili. Defendant admitted the act but claimed self-defense, alleging Agcaoili and others were attempting to break into his mother-in-law’s house to kill him and steal carabaos. The trial court rejected this defense, finding that Agcaoili and his companions were quietly conversing inside the house when Baoit suddenly attacked him.
The wounds actually took 3-4 months (over 90 days) to heal. However, the trial judge classified them as lesiones menos graves (less serious physical injuries) based on a physician’s opinion that they could have healed in 30-40 days with proper medical attendance. Agcaoili testified he lacked the means to pay for medical services. The attack was sudden and unprovoked, with no prior dispute.
ISSUE:
1. Should the classification of physical injuries be based on the actual healing time or the estimated healing time under ideal medical conditions, especially when the victim lacks means for proper medical care?
2. Did the sudden and unprovoked nature of the attack constitute treachery?
RULING:
The Supreme Court reversed the trial court’s judgment and ruled that:
1. The classification of physical injuries must be based on the actual time required for healing, not on the hypothetical time under optimal medical conditions. The defendant is responsible for all consequences arising from his act that cannot be imputed to the fault of the injured party. Since the wounds actually required more than ninety days to heal, the crime is properly classified as lesiones graves (serious physical injuries) under paragraph 3 of Article 416 of the Penal Code. The victim’s lack of means to secure proper medical attendance does not mitigate the defendant’s responsibility for the extended healing period.
2. Yes, the attack was treacherous. The injured party was engaged in a friendly conversation and was suddenly attacked without any prior trouble, dispute, or warning, rendering him entirely unable to take precautions against the aggression. This suddenness and lack of opportunity for defense constitute treachery, a qualifying circumstance under the last paragraph of Article 416.
Accordingly, Sabas Baoit was sentenced to three years six months and twenty-one days of prision correccional, to pay medical fees, and indemnify the victim.