G.R. No. L-6714, February 2, 1912
THE UNITED STATES vs. LORENZO MENDOZA

FACTS

The defendant, Lorenzo Mendoza, was charged with the crime of lesiones menos graves (less serious physical injuries). The trial court found that Mendoza summoned Fermin Castillo to his house and there assaulted him, causing injuries that incapacitated Castillo from work for ten days. The court sentenced Mendoza to four months of arresto mayor, an indemnity of 20 pesos to Castillo, and costs. Mendoza appealed, contesting the existence of injuries and the award of indemnity. The defense presented a physician who examined Castillo days after the incident and found no injuries, claiming Castillo feigned his symptoms. In contrast, the prosecution presented Castillo, his wife and son, and the president of the municipal board of health (a medical practitioner), who testified that Castillo had bruises, chest pains, spat blood, and was bedridden for ten days.

ISSUE

1. Whether the evidence sufficiently proves that Mendoza inflicted physical injuries on Castillo.
2. Whether the trial court validly awarded indemnity despite the absence of concrete proof of the exact amount of damages.

RULING

1. Yes. The Supreme Court upheld the trial court’s findings. The testimony of the prosecution witnesses, including the board of health president who examined Castillo shortly after the assault, was deemed more credible than that of the defense physician, who examined Castillo days later when superficial bruises might have healed. The trial judge’s assessment of witness credibility is accorded respect unless manifestly erroneous, which was not shown here.
2. Yes. The award of indemnity was valid. Under Article 121 of the Penal Code, courts have discretionary power to determine the amount of damages for injuries, even without concrete proof. This discretion considers factors such as the victim’s lost wages and the defendant’s financial capacity. The 20-peso indemnity was not excessive, given Castillo’s ten-day incapacity and Mendoza’s wealth. The Court affirmed the judgment, adding subsidiary imprisonment in case of non-payment.