GR 1331; (August, 1903) (Digest)
March 7, 2026GR 1430; (August, 1903) (Digest)
March 7, 2026G.R. No. 1307, August 21, 1903
THE UNITED STATES, complainant-appellee, vs. JOSE RAMOS, ET AL., defendants-appellants.
FACTS:
Anacleta, the daughter of defendant Jose Ramos, challenged Pascual Rodriguez to come out of his house. Pascual complied and, upon reaching the stairway, was met by Jose Ramos and his three sons: Mariano, Rufino, and Andres. Mariano and Rufino were positioned in front. Mariano attacked Pascual with a bolo, severing his left hand, while Rufino simultaneously struck him with a club, rendering him unconscious. The trial court acquitted Jose and Andres. It convicted Mariano and Rufino but imposed different penalties: four years, nine months, and eleven days of imprisonment on Mariano for causing the loss of a hand, and only four months on Rufino for causing a contusion. The prosecution appealed the sentences.
ISSUE:
Whether the trial court erred in imposing different penalties on Mariano Ramos and Rufino Ramos for their respective acts committed during a single, joint aggression.
RULING:
Yes. The Supreme Court reversed the judgment. The defendants Mariano and Rufino were joint participants in the same criminal aggression against Pascual Rodriguez. Under Article 13 of the Penal Code, each is liable for the combined result of their concerted acts. The court erred in treating their individual blows and resulting injuries separately for the purpose of penalty. The aggravating circumstance of nocturnity was not considered, as the evidence did not show the defendants chose the time (8 p.m.) to take advantage of the darkness. With no aggravating or extenuating circumstances, the penalty should be imposed in its medium degree. Both defendants were convicted of lesiones graves under Article 416, No. 2 of the Penal Code. Each was sentenced to four years, nine months, and ten days of prision correccional, jointly and severally ordered to indemnify Pascual Rodriguez in the amount of 500 Philippine pesos, and to pay half the costs of the first instance and the full costs of the Supreme Court proceedings.
