G.R. No. 10606 ; September 11, 1915
THE UNITED STATES, plaintiff-appellee, vs. ANDRES VILLANUEVA, defendant-appellant.

FACTS:
The defendant, Andres Villanueva, was charged with inflicting a serious wound upon Isidro Benter. The complaint alleged that during a quarrel, Villanueva suddenly snatched the bolo Benter was carrying at his belt and used it to wound Benter’s right palm, incapacitating him for over thirty days and rendering the hand entirely useless. The Court of First Instance of Mindoro convicted Villanueva of lesiones graves (serious physical injuries) through reckless negligence under Article 568 of the Penal Code and sentenced him accordingly.

At trial, the evidence revealed a different scenario. Benter testified that he had agreed to take Villanueva by boat to the town of Pola. Upon finding the boat unavailable, Benter suggested they start walking. While both were standing with arms folded, Villanueva, in good temper and without any prior quarrel or words, took hold of the bolo at Benter’s belt. Benter tried to retain it, and in doing so, he caught the blade, cutting his own palm. Benter immediately left without showing the wound to Villanueva. Two prosecution witnesses confirmed Benter was wounded but learned nothing from him about how it happened. The medical evidence showed a scar and some stiffness but did not prove the hand was entirely useless.

ISSUE:
Whether the act of the defendant, Andres Villanueva, constitutes the crime of serious physical injuries (lesiones graves) through reckless negligence.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted Andres Villanueva.

The Court held that the essential element of the crimethat the defendant “wounded, beat, or assaulted” the victimwas utterly lacking. The evidence conclusively showed that Villanueva did not inflict the wound. The injury was caused by Benter’s own act of instinctively grabbing the blade when Villanueva, without malice or threat, merely took hold of the bolo. The Court characterized Villanueva’s action as seemingly motivated by “mere curiosity.”

The Court further ruled that Villanueva’s act of taking the bolo from its sheath was not, in itself, a crime or misdemeanor defined by law. For a conviction of physical injuries through reckless negligence to stand, the accused must have performed an act that directly caused the injury. Here, the direct cause was the victim’s own reaction. The Court cited a analogous Spanish precedent where a defendant who raised a sickle in a threatening manner was acquitted because the victim’s injuries resulted from his own indiscretion in grabbing the tool.

Since the prosecution failed to prove that Villanueva wounded Benter, he cannot be held liable for serious physical injuries, whether willful or through reckless negligence. The Court ordered his acquittal, with costs de oficio.