Title
Pilares, Sr. vs. People
Case
G.R. No. 165685
Decision Date
Mar 14, 2007
Petitioner convicted of Serious Physical Injuries for attacking private complainant with a dull-edged object, causing incapacitation for over 30 days; Supreme Court affirmed guilt beyond reasonable doubt.
serious physical injuries
assault
bladed weapon

Case Summary (G.R. No. 165685)

Factual Background

The prosecution evidence centered on an altercation involving petitioner, the private complainant Pedro Bantigue, Jr. y Tanjutco, and petitioner’s son, Reynaldo Pilares, Jr. On 16 January 1994 at around twelve o’clock in the morning, the private complainant—described as a movie stuntman and a driver for an international firm—arrived home with the assistance of Ernesto Mangunay, his brother-in-law. Mangunay’s car broke down due to engine overheating at about one o’clock in the morning, prompting the men to park the car at a nearby chapel and wait for it to cool. Due to boredom, they purchased beer. The store where they bought beer was owned by petitioner.

While handing over bottles of beer, petitioner allegedly prohibited drinking liquor within and near the store. The private complainant and Mangunay initially drank, but verbal bickering occurred. The private complainant claimed that when he demanded change after petitioner’s refusal of the initial payment, petitioner became irked, stepped out holding a one-foot bladed weapon, and approached. The private complainant stated that Reynaldo Pilares, Jr. emerged armed with a kitchen knife and followed petitioner. The private complainant fled; after running about one hundred meters, he stumbled and fell. While he lay on his back, Reynaldo Pilares, Jr. allegedly approached to stab him, and the private complainant swerved to avoid the stab. The private complainant was then hit on the right side of his face, particularly the right cheekbone, by Reynaldo Pilares, Jr.’s kitchen knife. After that, petitioner allegedly closed in and attempted to stab him again. The private complainant claimed he parried with his left foot and rolled toward a fence until someone shouted “Tama na yan! Tigilan na yan!” Petitioner and Reynaldo Jr. then left the private complainant.

The private complainant reported that he was brought first to Malhacan Hospital and later transferred to Manila Central University Hospital (MCU Hospital), where he was treated for three days. He claimed expenses of P9,000.00 for the physician’s professional fee and asserted that the injury incapacitated him for more than thirty days and required medical attendance.

Medical Evidence and Characterization of the Wounds

Dr. Francisco C. Rodriguez, a physician-surgeon assigned to MCU Hospital, testified that the private complainant suffered multiple deep lacerations on the face, especially: (a) a laceration from the cheekbone down to the lower lip measuring fifteen centimeters; (b) a laceration on the lower right lip measuring one centimeter; and (c) a laceration near the left side of the upper lip measuring two centimeters, with an additional abrasion on the forehead. Dr. Rodriguez explained that these injuries could be caused by a dull-edged or blunt instrument, such as a dull knife or blunt weapon, rather than an incised wound from a sharp kitchen knife. He further stated that the depth and location of the lacerations implied risks such as facial effects—described as possible squinting and frequent eye blinking—should the condition not be treated properly due to proximity to the facial nerve.

Dr. Rodriguez emphasized that the injuries could not have been caused by a kitchen knife, because that would ordinarily produce a cleanly cut incised wound. He also reasoned that the wounds could not have resulted from the private complainant hitting a metal object or rough pavement during his fall, because such a scenario would likely produce more abrasions than lacerations. He also opined that the private complainant was facing his attacker at the moment the injuries were inflicted, and that the wound’s pattern suggested an upward thrust.

Defense Version

Petitioner denied that the injuries were inflicted by a kitchen knife and provided a narrative centered on his own confrontation with the private complainant and the lack of personal quarrels between them. He testified that he did not immediately accede when the private complainant asked for beer on 15 January 1994 around ten o’clock in the evening. He described multiple subsequent visits by the private complainant and Mangunay, during which the private complainant allegedly acted confrontational and insulting. Petitioner stated that at around one o’clock in the morning, when the private complainant called him a coward and dared him to fight, petitioner chased the private complainant, but failed to catch him. Petitioner added that the private complainant allegedly threw stones at him during the pursuit.

Petitioner acknowledged that when he was chasing the private complainant, he carried a plastic material wrapped in a newspaper, with a chisel-like edge, which he used for picking ice and killing rats. He admitted that he held this object vertically in his right hand and punched the private complainant on the left jaw using the same hand, but denied that the object touched, hit, or slashed the private complainant’s face because of its alleged vertical position. Petitioner also asserted that Reynaldo Jr. had no participation in the verbal tussle, chase, and confrontation, claiming that Reynaldo Jr. was sleeping upstairs during the incident and was later already on his way home when he encountered Reynaldo Jr.

Reynaldo Pilares, Jr. corroborated petitioner’s claim that he was sleeping upstairs during the incident. He testified that at around one o’clock in the morning, his elder sister woke him and told him to follow petitioner because petitioner and Bantigue were quarreling. He claimed that he met petitioner a short distance from the house and that petitioner told him to go home because “nothing of importance had happened.” He later claimed that petitioner pointed out the incident area and that he did not see bloodstains where the private complainant allegedly tripped and fell.

Proceedings in the Trial Court and the Court of Appeals

The RTC, in its Decision dated 13 November 1996, convicted petitioner of Serious Physical Injuries under Article 263, paragraph 3 of the Revised Penal Code, while acquitting Reynaldo Jr. The RTC did not credit the private complainant’s testimony attributing the right cheek injury to Reynaldo Jr. as carrying a kitchen knife. Instead, it relied on Dr. Rodriguez’s findings and held that the wounds were more consistent with a dull-edged or blunt instrument. The RTC concluded it was highly probable that when petitioner punched the private complainant, the dull-edged object he carried slashed the face upward “from the latter’s lower lip up to his right cheekbone.” It also found no convincing evidence of intent to kill and no conspiracy between petitioner and Reynaldo Jr. to kill the private complainant.

On appeal, the Court of Appeals Decision dated 28 March 2000 affirmed the conviction but modified the legal classification. It held petitioner liable for serious physical injuries under Article 263, paragraph 4, reasoning that the allegations in the Information clearly pertained to paragraph 4. Thus, it modified the sentence imposed while maintaining the finding of guilt.

Issues Raised by Petitioner

In his Supreme Court petition, petitioner contended that both the RTC and the Court of Appeals erred by not declaring that his guilt was not proven beyond reasonable doubt and by failing to adhere to Section 2, Rule 133 of the Rules of Court. He argued that there was no evidence that he inflicted the injuries on the face, emphasizing that the private complainant allegedly identified Reynaldo Jr. as the person who inflicted the wounds on the right cheek. Petitioner also argued that Mangunay did not actually see who inflicted the wounds. He further claimed that his age and alleged ailments rendered it improbable that he inflicted serious harm compared to a younger, stronger stuntman.

Finally, petitioner maintained that because he allegedly held the plastic material vertically when he punched, it could not have slashed the private complainant’s face, and that the lacerations might have resulted from the private complainant’s fall onto rough pavement.

Legal Basis and Reasoning

The Supreme Court reiterated that guilt in criminal cases must be proven beyond reasonable doubt, requiring moral certainty on each element essential to establish the offense and the accused’s criminal responsibility. It emphasized that proof beyond reasonable doubt does not require absolute certainty, but it demands that the mind of the trial judge can rest at ease concerning its verdict.

The Court then focused on the statutory elements of serious physical injuries under Article 263, paragraph 4 of the Revised Penal Code. It stated that the offense is committed when a person wounds, beats, or assaults another and the physical injuries cause illness or incapacity for labor for more than thirty days. It further noted that there must be no intent to kill on the part of the offender in inflicting the injury.

Applying the evidence, the Court held that the prosecution established identity of the malefactor—petitioner—and the existence and infliction of injuries on the private complainant’s face. The disputed matters involved co-participation of Reynaldo Jr., the presence of intent to kill, and justification in the infliction of injuries.

On identity and weapon compatibility, the Supreme Court found petitioner’s admissions significant. Petitioner admitted he carried the plastic material with a chisel-like edge during the chase and admitted that he held the same object in his right hand when he punched the private complainant on the face. The Court also took into account that petitioner’s narrative did not convincingly rebut the pattern and character of the injuries described by Dr. Rodriguez.

Dr. Rodriguez’s testimony was treated as probative. The Court agreed with the lower courts’ analysis that the injuries could not have been caused by a kitchen knife because the wounds were lacerations consistent with a dull-edged or blunt instrument, not cleanly cut incised wounds. Dr. Rodrigue

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