G.R. No. L-10319; February 26, 1915
THE UNITED STATES, plaintiff-appellee, vs. CRISPINA GANZON, defendant-appellant.

FACTS:
The defendant-appellant, Crispina Ganzon, was convicted by the Court of First Instance of Bataan for the crime of injurias graves (grave insults). She was sentenced to six months and one day of destierro (banishment) within a radius of twenty-five kilometers from the municipal building of Abucay, a fine of 225 pesetas, and costs.

The conviction arose from a bitter altercation between Ganzon and the complaining witness, Maximina Mina. During the quarrel, both parties exchanged offensive and scurrilous epithets in the heat of passion.

ISSUE:
Whether the offensive language used by the defendant during the altercation constitutes the crime of injurias graves or merely the misdemeanor of slight insults under Article 589 of the Penal Code.

RULING:
The Supreme Court REVERSED the judgment of the lower court. It held that the language used, while offensive, was uttered in the heat of passion without deliberate intent for its literal meaning to be taken seriously. Under the circumstances, the exchange constituted a mere misdemeanor under Article 589(1) of the Penal Code (slight insults), not the more serious crime of injurias graves.

The Court modified the sentence. Crispina Ganzon was found guilty of the misdemeanor under Article 589 and sentenced to pay a fine of 25 pesetas. She was also ordered to pay the costs of a juicio verbal (summary procedure), as is customary in convictions for misdemeanors in justice of the peace courts. The costs of both instances were declared de oficio.