G.R. No. 224302 - Aguinaldo vs. Aquino III

On November 25, 2017 at around 10:45 a.m. in Parañaque City, private complainant Roberto Amado Hatamosa was walking to his workplace when accused Pastor Corpus, Jr. allegedly intercepted him, shouted threats, and punched him in the face. Witnesses testified that Pastor’s blow caused Roberto’s bloody nose and required between three to nine days of medical treatment.
Roberto’s Medico-Legal Report, however, also noted a complete fracture at the proximal end of the fifth digit of the right hand. On April 30, 2018, the Senior Assistant City Prosecutor, construing the fracture as a “disfigurement,” recommended indicting Pastor and two others for serious physical injuries under Article 263(3) of the Revised Penal Code (RPC).

An Information for serious physical injuries was filed on May 21, 2018. Upon arraignment, Pastor pleaded not guilty, and trial on the merits proceeded.
In its November 20, 2018 Decision, the Metropolitan Trial Court (MeTC) found no evidence linking Pastor to the finger fracture but established that he caused slight physical injuries (bloody nose, incapacity of three to nine days). The MeTC convicted him of slight physical injuries under Article 266 RPC and imposed arresto menor (30 days) with moral damages of ₱10,000.

On March 20, 2019, the Regional Trial Court (RTC) Branch 257 affirmed the MeTC’s conviction.
The Court of Appeals (CA), on March 13, 2020, likewise affirmed the RTC Decision and later denied Pastor’s Motion for Reconsideration on February 10, 2021.
Pastor filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, arguing in particular that the crime of slight physical injuries had prescribed when the Information was filed.

Whether the factual issues raised by Pastor are beyond the scope of a Rule 45 petition.
Whether the CA correctly held that the Information charging Pastor with serious physical injuries had not prescribed.
Whether the CA correctly affirmed Pastor’s conviction for slight physical injuries.