G.R. No. 80879 - Saavedra, Jr. vs. Securities and Exchange Commission

The case involves the United States as Plaintiff and Appellee versus Juan Bogel (alias Catalin) and others as Defendants and Appellants.
The accused were charged with robbery with violence or intimidation to the person.
Guilt was proven beyond a reasonable doubt.

During the commission of the robbery, one of the accused stabbed a woman named Fabiana in one eye.
As a result of the stabbing, Fabiana lost the use of the affected eye.
The injury was directly connected to the robbery, thus being an aggravating circumstance in the commission of the crime.

The trial court initially imposed the penalty prescribed in paragraph 2 of Article 503 of the Penal Code.

Paragraph 2 applies when robbery is accompanied by rape, intentional mutilation, or when wounds penalized by paragraph 1 of Article 416 are inflicted, or when the victim is held prisoner for ransom or for more than one day.

The appellate court, however, held that the proper penalty to be imposed is that prescribed in paragraph 3 of Article 503.

Paragraph 3 mandates penalties with “cadena temporal” when, for the purpose of or on occasion of the robbery, any of the wounds inflicted are those penalized in paragraph 2 of Article 416.
Paragraph 2 of Article 416 punishes grave injuries such as loss of an eye, some principal member, or incapacitation affecting one’s habitual work.

The trial record provided that the exsanguinating wound upon Fabiana’s eye did not fall under the definition of "mutilation" as recognized under the law.
Commentary by Viada on Article 415 explained that "mutilation" (mutilacion) is understood as the lopping or clipping off (cercenamiento) of some part of the body.
Since the injury involved the stabbing and consequent loss of use of an eye rather than the lopping off of the eye, it did not meet the criteria for intentional mutilation.

The robbery took place at night.
It occurred in the house of the offended party, adding to the gravity of the crime.
The robbers had disguised themselves, a measure taken to enhance the security of their commission of the act.

The trial judge had imposed the penalty as per paragraph 2 of Article 503 in its medium degree.
The appellate court ruled that, given the nature of the inflicted injury and the definition of mutilation, the appropriate penalty should be imposed under paragraph 3 of Article 503.
Accordingly, the penalty applicable is “cadena temporal in its maximum degree.”

Whether the stabbing of Fabiana’s eye, resulting in her losing the use of the eye, should be considered intentional mutilation under the definition provided in the penal statutes.

Does the injury meet the definition of "mutilation" as described in Viada’s commentary and the Diccionario de la lengua?
What is the proper classification of the injury under Article 416 of the Penal Code?

Which paragraph of Article 503 should govern the penalty — Paragraph 2 (medium degree) or Paragraph 3 (maximum degree) — given the circumstances of the case?
How do the aggravating factors (robbery at night, in the residence of the offended party, and the offenders’ use of disguises) influence the determination of the correct penalty?

Is the interpretation of the term "mutilation" correct as applied by the trial court?
Should the lower court have opted for the penalty prescribed in paragraph 3 of Article 503 based on the facts and the definitions provided?