G.R. No. and Date: G.R. Nos. L-9169 and L-9170, March 14, 1914

FACTS:
Two separate criminal cases were tried and decided together by the Court of First Instance of Pangasinan. In the first case (G.R. No. L-9169), defendants Pantaleon Mariano and Roberto Mariano were charged with and convicted of the crime of lesiones (physical injuries) for attacking and wounding a complaining witness with a bolo on December 22, 1912. In the second case (G.R. No. L-9170), the same defendants, along with Cecilio Mariano and Marcelo Mariano, were charged with and convicted of the crime of homicide for inflicting fatal wounds on Juan Cortez on the same night, resulting in his death ten days later. The trial court, in both judgments, found the aggravating circumstance of nocturnity present. However, the court failed to include in its decisions a statement of the facts upon which the convictions were based. It also failed to specify the kind of penalty imposed or cite the provision of the Penal Code under which the penalty was applied, merely stating the prison terms and indemnities.

ISSUE:
Whether the trial court’s decisions are legally deficient for failing to contain a statement of facts and a proper description of the penalty imposed.

RULING:
Yes. The Supreme Court ruled that a decision in a criminal case must contain a statement of the facts upon which the conviction is based and must describe the penalty imposed, citing the provision of law applied. This requirement is essential, especially for review by the Supreme Court, which must examine the facts in all criminal appeals. Consequently, the Supreme Court remanded both cases to the Court of First Instance with instructions to formulate a proper statement of facts and to impose the penalty in accordance with the law. The court further held that an appeal from the new decision and sentence could be taken as if it were the first judgment in the case.