Case Digest (G.R. No. 234812)
Facts:
In Elpedio Ruego v. People of the Philippines, petitioner Elpedio Ruego was charged by Information dated October 27, 2005, before the Municipal Trial Court in Cities of Iloilo City with serious physical injuries under Article 263(3) of the Revised Penal Code. It alleged that on September 5, 2005 at around 10:30 p.m. along Paho Road, Barangay South Fundidor, Molo, Iloilo City, Ruego, without justifiable motive, struck respondent Anthony M. Calubiran, fracturing his upper right central incisor and causing a permanent deformity. Prosecution witnesses, including barangay officials and bystanders, testified that Ruego insulted Calubiran, punched him unprovoked, and even pushed away police officers who tried to intervene. A medico-legal examination by Dr. Owen Jaen Libaquin confirmed head trauma and a fractured incisor, which was later replaced by an artificial tooth. Ruego pleaded not guilty on August 2, 2006; the MTC convicted him on December 15, 2011; the Regional Trial Court affir...Case Digest (G.R. No. 234812)
Facts:
- Charge and Arraignment
- On September 5, 2005, Elpedio Ruego was charged by Information in Iloilo City with Serious Physical Injuries under Article 263(3) of the Revised Penal Code for fracturing Anthony M. Calubiran’s upper right central incisor, allegedly causing permanent deformity.
- Ruego was arraigned on August 2, 2006, and pleaded not guilty. Trial on the merits commenced thereafter.
- Incident and Witness Testimony
- Prosecution witnesses June Alfred Altura, Calubiran, Raden Selguerra, and Selguerra’s father testified that at around 10:30 p.m. on September 5, 2005, along Paho Road, Ruego challenged Calubiran (“What are you looking at?”) and punched him. Attempts to mediate by barangay officials failed.
- Police blotter entries confirmed the report to the Philippine National Police. Ruego’s group had fled before police arrival.
- Medical Examination and Injury
- Dr. Owen Jaen Libaquin, medico-legal officer, found Calubiran sustained head injuries and a fractured upper right central incisor, which he opined caused permanent deformity.
- At trial, Calubiran showed an artificial tooth—evidence that the fractured tooth had been repaired by an unspecified modern dental procedure.
- Defense Case
- Ruego and his witness Leomar Tondo (“Ok-Ok”) claimed Calubiran, allegedly drunk, threw the first punch after staring at Ruego. They asserted mutual agreement to a fistfight, with Ruego acting in self-defense.
- Ruego denied deliberate intent and disputed that the tooth fracture amounted to permanent deformity.
- Judicial Proceedings
- The Municipal Trial Court in Cities of Iloilo (Dec. 15, 2011) and the Regional Trial Court (Aug. 17, 2012) convicted Ruego of serious physical injuries. The Court of Appeals (Jan. 26, 2016) affirmed, holding the loss of a front tooth causing permanent deformity falls under Article 263(3).
- Ruego’s motions for reconsideration were denied at each level. This petition for review on certiorari under Rule 45 followed.
Issues:
- Whether this Court may review factual findings in a criminal appeal under Rule 45.
- Whether fracturing and later medically repairing a single tooth constitutes “serious physical injuries” (deformity or loss of a body part) under Article 263(3) of the Revised Penal Code.
- Whether the equipoise rule applies, given the claim of mutual fistfight agreement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)