G.R. No. 1987 : March 27, 1905
THE UNITED STATES, complainant-appellee, vs. APOLONIO MAÑAUL, ET AL., defendants-appellants.

FACTS:
The defendants were charged with the crime of lesiones graves (serious physical injuries) for having cut off both ears of Placida Gonzalez on the evening of June 30, 1903. The trial court found them guilty and sentenced them to six years of prision correccional and costs. The court applied Article 416 of the Penal Code, imposing the penalty in its maximum degree due to the presence of aggravating circumstances: that the crime was committed at night, for a promise or reward, with the use of superior force, and in the house of the injured party.

ISSUE:
Whether the trial court correctly considered all the alleged aggravating circumstances, particularly the circumstance that the crime was committed in the house of the injured party.

RULING:
The Supreme Court affirmed the conviction and the penalty imposed, but modified the assessment of aggravating circumstances. The Court agreed with the trial court’s findings of fact and law, and concurred that the crime fell under Article 416 of the Penal Code, as the loss of both ears caused the victim’s deafness. The Court also agreed with the existence of the aggravating circumstances of nocturnity, promise of reward, and use of superior force.

However, the Supreme Court held that the aggravating circumstance of dwelling was not present. The evidence clearly established that the defendants made the victim come out of her house to consummate the crime; therefore, the offense was committed outside her dwelling. With this modification, the judgment was affirmed. The defendants were credited with one-half of their preventive imprisonment.