G.R. No. L-11451, October 19, 1916
THE UNITED STATES, plaintiff-appellee, vs. DOMINGO PEREZ and ERNESTO PEREZ, defendants-appellants.

FACTS:
The defendants, Domingo Perez and Ernesto Perez, were charged with and convicted by the trial court of the crime of grave physical injuries under subsection 4 of Article 416 of the Penal Code. The trial court found that they acted in concert to assault the complaining witness, inflicting injuries that allegedly rendered him ill and incapacitated for labor for more than 30 days. Consequently, the court imposed a penalty of one year and one day of prision correccional. On appeal, the defendants challenged the conviction.

ISSUE:
Whether the evidence sufficiently proves that the physical injuries inflicted upon the complaining witness were of such gravity as to constitute the crime of grave physical injuries under Article 416(4) of the Penal Code, specifically whether the injuries incapacitated the victim for labor for more than 30 days.

RULING:
The Supreme Court REVERSED the judgment of the trial court. While it affirmed the factual finding that both defendants acted in concert in assaulting the complaining witness, it held that the evidence failed to establish beyond reasonable doubt that the injuries inflicted were grave.

The Court noted a conflict in the medical evidence. The provincial health officer, who examined the victim on the day of the assault, testified that the injuries were not serious and would require medical attention for only a few days. In contrast, a private practitioner, who treated the victim later, testified that the injuries were grave and caused incapacity for over a month. The Court found the testimony of the provincial health officer to be more credible, clear, consistent, and unbiased. It observed that the testimony of the private practitioner and the complaining witness contained inconsistencies and appeared to be exaggerated or influenced by partisan interest.

The Court concluded that the injuries, while preventing labor and necessitating medical attendance for more than one day, did not incapacitate the victim for more than seven days. Therefore, the facts did not constitute grave physical injuries under Article 416(4) but instead constituted the lesser misdemeanor of slight physical injuries under Article 587 of the Penal Code.

The defendants were convicted of the misdemeanor under Article 587 and sentenced to 15 days of arresto menor, with payment of the costs in the Court of First Instance. Costs of the Supreme Court proceeding were de officio.