G.R. No. L-412, November 16, 1901
THE UNITED STATES, complainant-appellee, vs. CAYETANO ABALOS, defendant-appellant.

FACTS:
On the evening of October 23, 1900, in Santa Maria, Ilocos Sur, six unknown persons approached the house of Pedro Pascua. When Pascua, out of fear, did not comply with an order to come down, one of them, later identified as Cayetano Abalos, went up the house. Without any apparent motive, Abalos attacked Pascua with a dagger, inflicting five wounds. Two wounds, on the chest and abdomen, were serious and dangerous. Pascua recovered after thirty-one days but was left with a hernia from the abdominal wound. Abalos immediately fled. He was recognized during the assault by Pascua and two eyewitnesses. Abalos remained absent from his home until his arrest on April 3, 1901, despite judicial citations. The Court of First Instance convicted him of grave assault. On appeal, the Solicitor-General argued that the judgment was null because it was rendered after June 16, 1901, by a judge whose court had been replaced by a new organic law (Act No. 136) effective on that date.

ISSUE:
1. Whether the guilt of Cayetano Abalos for the crime of grave assault was proven beyond reasonable doubt.
2. Whether the judgment of the Court of First Instance is null and void because it was rendered by a judge after the effective date of the new organic law which reorganized the courts.

RULING:
1. On the Criminal Liability: Yes. The Supreme Court affirmed the conviction. The positive identification by the victim and two eyewitnesses, corroborated by the testimonies of neighbors and the accused’s unexplained flight and absence, established his guilt beyond reasonable doubt. The crime constituted grave assault (lesion grave) under Article 416, No. 3 of the Penal Code. The aggravating circumstances of nocturnity and attack in the victim’s dwelling (Article 10, Nos. 15 and 20) were present, with no mitigating circumstances. The penalty was imposed in its maximum degree.

DISPOSITIVE:
The appealed judgment was affirmed with modification. Cayetano Abalos was sentenced to four years of prision correccional with accessory penalties, to indemnify Pedro Pascua in the amount of 100 pesos (with subsidiary imprisonment in case of insolvency), and to pay the costs. His provisional imprisonment was not credited, pursuant to the applicable rules.