Here’s the digest of the PH case:

FACTS:
On the evening of September 17, 1892, in Calaca, Batangas, Engracio Ronimo, a town lieutenant, intervened in a quarrel between Eleuterio Marasigan and Severino Magsino inside Geronimo Ramos’s house. When Ronimo attempted to take them to the municipal building, Arcadio de Joya, the justice of the peace, arrived and, after a conversation with Marasigan, appeared to be arranging a settlement. Ronimo objected to this. Marasigan then grabbed the gun carried by de Joya and shot Ronimo in the head, causing him to fall. Ronimo sustained a gunshot wound to the left parietal region of the head, affecting only the scalp without penetrating the skull. Medical examination indicated that the wound would heal completely within 20 to 30 days, classifying it as lesiones menos graves.

Marasigan and de Joya were charged with lesiones graves. The trial court, on May 2, 1896, sentenced Marasigan for “discharging a firearm and lesiones graves” to three years and six months of prision correccional, with accessory penalties and indemnity. De Joya was acquitted. Marasigan appealed, subsequently disappeared, and was declared in default. His counsel later claimed a pardon from the “former sovereignty” but failed to produce proof. The Solicitor-General moved to affirm the judgment.

ISSUE:
Whether the trial court correctly classified the crime and imposed the appropriate penalty for Eleuterio Marasigan’s act of shooting Engracio Ronimo, considering the concurrent offenses arising from a single act.

RULING:
The Supreme Court affirmed the judgment of the trial court.

The Court held that the proven facts constituted the crime of discharge of a firearm causing lesiones menos graves. It clarified that the act could not be classified as armed aggression against an agent of authority, as Ronimo was not acting in an official capacity at the moment of the shooting (the justice of the peace was present and the quarrel was private). Neither could it be classified as frustrated murder or homicide due to insufficient proof of intent to kill.

The Court found that Marasigan’s single criminal act of discharging a firearm against Ronimo resulted in two offenses:
1. Discharging a firearm against a person (Article 408 of the Penal Code).
2. Lesiones menos graves (Article 418 of the Penal Code).

Applying Article 89 of the Penal Code (complex crime), which states that whenever a single act constitutes two or more crimes, the penalty corresponding to the more serious crime shall be imposed in its maximum degree. Since no mitigating or aggravating circumstances were present, the penalty was correctly imposed in the medium grade of the maximum degree. The Court found that the penalty of three years and six months of prision correccional imposed by the trial court was in accordance with the law under this complex crime doctrine. The claim of pardon was rejected due to lack of evidence.