G.R. No. 165685 - Pilares, Sr. vs. People

On or about January 16, 1994, in Meycauayan, Bulacan, petitioner Reynaldo R. Pilares, Sr. and his son, Reynaldo Pilares, Jr. were charged in an Information for Frustrated Homicide.
The criminal incident allegedly began at the petitioner’s store when the private complainant, Pedro Bantigue, Jr.—a movie stuntman and driver—visited the establishment with his brother-in-law, Mangunay, after their car broke down near a chapel.
A verbal altercation ensued over the purchase of beer, beginning with a dispute on payment and culminating in the petitioner using a one-foot bladed weapon to confront the private complainant.

The complainant narrated that after purchasing beer for three rounds from the petitioner’s store, a heated verbal exchange occurred.
He testified that following the confrontation, the petitioner, armed with a knife, chased him and, along with Reynaldo Jr. (who emerged armed with a kitchen knife), caused him to stumble during the pursuit.
As he fell, the complainant sustained injuries on the right side of his face including deep lacerations and abrasions, which required hospitalization and medical treatment for over 30 days.

Mangunay, the complainant’s brother-in-law and a resident of Meycauayan, corroborated the timeline of events starting with the car breakdown, the decision to drink inside the car, and subsequent visits to the petitioner’s store.
He described the repeated confrontations at the store, noting that after the final purchase and return of empty bottles, an escalated confrontation occurred leading to the chase.

Dr. Rodriguez, the attending physician at MCU Hospital, confirmed that the complainant suffered multiple deep lacerations on his face, including a long cut extending from the lower lip to the right cheekbone, one smaller laceration on the lower right lip, and another on the upper lip.
His findings noted that the injuries were most consistent with a dull-edged or blunt instrument rather than a clean incised cut that would be expected from a sharp kitchen knife.

The petitioner presented his account stating that the incidents began with a dispute over beer purchases with no prior quarrel with the complainant, emphasizing that his confrontation was verbal before a physical chase ensued.
He admitted to chasing the complainant and punching him on the left jaw while holding an object described as a plastic material with a chisel-like edge—commonplace for picking ice and killing rats.
Reynaldo Jr. stated that he was initially asleep and was only summoned after the incident had begun; he claimed minimal to no participation and recounted meeting his father on their way home.

The Regional Trial Court (RTC), Branch 77, Malolos, Bulacan rendered a Decision on November 13, 1996, finding petitioner guilty of the crime of Serious Physical Injuries under Article 263, paragraph 3 of the Revised Penal Code and acquitting Reynaldo Jr.

The RTC held that the physical injuries inflicted on the private complainant were caused by the dull-edged object used by the petitioner when he punched him, resulting in a slash from the lower lip to the right cheekbone.
The court noted the possibility that the complainant’s attempt to implicate Reynaldo Jr. might have been an effort to shift blame onto a younger relative with a brighter future.

On March 28, 2000, the Court of Appeals affirmed, with modification, the RTC’s Decision, modifying the basis of conviction to align with paragraph 4 of Article 263.
The appellate Decision emphasized that the elements of serious physical injuries were met, particularly highlighting the duration (over 30 days) of illness and incapacity for labor resulting from the injuries.

There was insufficient evidence to prove beyond reasonable doubt that he inflicted the injurious wounds on the complainant’s face.
The complainant himself had identified Reynaldo Jr. as the aggressor regarding the facial injuries.
Considering his advanced age (66 years at the time) and weakened physical condition, he could not have caused the serious injuries as alleged.

He contended that the manner in which he held the said object (vertically) would have been incapable of slashing the complainant’s face, and that any deep lacerations could have resulted from the complainant falling on rough pavement.
Petitioner further maintained that the overall evidence and circumstances did not establish an intent to kill.

Whether the evidence presented at trial, including testimonies and medical reports, proved beyond reasonable doubt that petitioner inflicted the classified serious physical injuries on the face of the private complainant.
Whether the physical evidence and testimonies support the contention that the injuries were caused by a dull-edged instrument in the manner alleged by the petitioner, as opposed to a sharp instrument claimed by the complainant.

Whether the identification and actions of petitioner, as established by witness testimony (including his own admission of possessing a plastic material with a chisel-like edge), are sufficient to hold him criminally liable under Article 263, paragraph 4.
Whether the evidence is strong enough to exonerate Reynaldo Jr., especially given conflicting accounts regarding his participation and the nature of the weapon allegedly used by him.

Whether the courts erred in their calibration of the evidence, particularly on the issue of intent to kill and participation in the aggressive act.
Whether the discrepancy in the alleged weapon’s nature (dull-edged versus a kitchen knife) has been adequately resolved in favor of the prosecution’s version of events.