G.R. No. 211017 - Tirol vs. Tayengco-Lopingco

Parties Involved:

Incident Details:

Date and Place: On or about September 11, 1956, in the municipality and province of Surigao, Philippines.
Nature of the Incident: Miguel Lasala was accused of committing serious slander by deed with less serious physical injuries and damages against Wenceslao Andanar, the incumbent municipal mayor of Sapao, Surigao.
Specific Allegations:

Lasala allegedly attacked, assaulted, and used fistic blows on Andanar in a public place (a cockpit) where many people were present.
The attack caused Andanar to suffer bruises and contusions, requiring 14 days of medical treatment and incapacitating him from his customary labors for 12 days.
The act was allegedly committed with the intent to expose Andanar to public ridicule, contempt, and dishonor.
Andanar claimed to have suffered mental anguish, wounded feelings, besmirched reputation, and social humiliation, seeking P30,000 in damages.

Procedural History:

Before arraignment, Lasala filed a motion to quash the information, arguing that the act constituted a single offense under Article 265, paragraph 2, of the Revised Penal Code (less serious physical injuries with intent to insult), rather than the complex crime of serious slander by deed with less serious physical injuries.
The trial court granted the motion, ordering the prosecution to amend the information to charge only the single offense of less serious physical injuries.
The prosecution’s motion for reconsideration was denied, leading to the present appeal.

Whether the acts committed by Miguel Lasala constitute the complex crime of serious slander by deed with less serious physical injuries under Article 48 of the Revised Penal Code.
Whether the acts fall under the specific provision of Article 265, paragraph 2, of the Revised Penal Code, which penalizes less serious physical injuries with the manifest intent to insult or offend the injured person.