G.R. No. L-5098
THE UNITED STATES, plaintiff-appellee, vs. VENANCIO MONASTERIAL, ET AL., defendants-appellants.
October 29, 1909

FACTS:
On July 21, 1908, at 9 p.m. in Ligao, Albay, Fruto Payoyo was stopped by brothers Aurelio and Venancio Monasterial. Aurelio confronted Payoyo about allegedly telling their father that they were hiring out his carabaos. Despite Payoyo’s denial, Venancio grabbed his shirt and punched him on the head, and immediately thereafter, Aurelio struck him with a stick. Payoyo attempted to block the blow with his left arm, which resulted in a fracture. The injury, due to articular complications, prevented Payoyo from working and using his arm freely for more than ninety days, although eventual complete recovery was possible.

The provincial fiscal charged both brothers with lesiones graves (serious physical injuries). The trial court convicted them, sentencing each to one year and one day of prision correccional, jointly and severally to indemnify the injured party for medical expenses and lost work, plus corresponding subsidiary imprisonment. The accused appealed the judgment.

ISSUE:
Whether Aurelio and Venancio Monasterial are criminally liable for the crime of lesiones graves and for all the consequences of the injuries inflicted upon Fruto Payoyo.

RULING:
Yes, the Supreme Court found Aurelio and Venancio Monasterial criminally liable for the crime of lesiones graves under Article 416, paragraph 3, of the Penal Code.

The Court held that the evidence conclusively proved that both brothers simultaneously attacked Payoyo, commencing with Venancio’s punch and immediately followed by Aurelio’s stick blow, which fractured Payoyo’s arm. The Court found that the two accused acted by mutual agreement and with a common purpose of injuring Payoyo, and their aggression was unprovoked.

The Court further ruled that all those responsible for a criminal act are equally liable for all the consequences arising therefrom and inherent therein, including complications that are not due to circumstances completely foreign to the act or the fault of the injured party. In this case, the prolonged incapacity of Payoyo due to complications was a direct consequence of the initial injury inflicted by the accused.

Finding no mitigating or aggravating circumstances, the Court reversed the trial court’s penalty, sentencing each of the accused to one year, eight months, and twenty-one days of prision correccional, along with accessory penalties, joint and several indemnification to the offended party as stated in the lower court’s judgment, corresponding subsidiary imprisonment, and half the costs of both instances for each.