Case Summary (G.R. No. 255038)
Crime and Initial Judgment
Filemon Bayutas was charged with the crime of lesiones graves, or serious physical injuries. On November 25, 1914, the trial court found Bayutas guilty and sentenced him to one year and a day of prision correctional, an indemnity of P50 for the medical treatment provided to Paras, subsidiary imprisonment for failure to pay, and the payment of court costs. Following this judgment, Bayutas appealed.
Factual Background of the Incident
On the night of the incident, after Esteban Paras and Alfonso Carvajal concluded a game of billiards, Bayutas suggested betting against Paras. Despite Paras's objections, Bayutas struck him from behind with a piece of hard wood, inflicting severe injuries. Witnesses confirmed that the initial blow hit Paras on the nape, and a subsequent strike rendered him unconscious. Dr. Cesar Mercader later examined Paras, identifying contused wounds that required 58 days to heal.
Defense Claims and Contradictions
Bayutas claimed he was provoked by Paras's challenges to fight and acted in self-defense when Paras allegedly attacked him with a billiard cue. However, the court noted significant contradictions between the testimonies of Bayutas and Paras, particularly regarding the nature and sequence of the events.
Testimony and Medical Evidence
The eyewitness testimonies reinforced the claim that Bayutas initiated the attack when Paras was vulnerable and not in a position to defend himself. Medical evidence indicated the direction and severity of the wounds supported the assertion that the attack was not an act of self-defense, as Bayutas struck from an advantageous position.
Legal Classification and Penalty
The court classified the act as a crime of lesiones graves, qualified by treachery, as provided for in Article 416 of the Penal Code. The attacking method employed by Bayutas indicated the absence of any immediate danger to himself, highlighting premeditated intent to injure. Despite the severity of the injuries, it was noted that the injuries were ultimately healed without lasting consequences, which informed the court's decision on the penalty.
Extenuating Circumstances and Final Judgment
The court recognized that the provocation from Paras may have contributed to Bayutas's loss of self-control, allowing for the consideration of mitigating circumstances. Thus,
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Case Overview
- The case involves the appeal of Filemon Bayutas, who was convicted of lesiones graves (serious physical injuries) and sentenced by the Court of First Instance of Cebu.
- The initial complaint was filed by the deputy provincial fiscal on October 21, 1914, regarding an incident that occurred on the night of October 8, 1913.
- The court imposed a penalty of one year and one day of prision correctional, indemnity of P50 for medical expenses, with the possibility of subsidiary imprisonment in case of insolvency, and ordered the payment of costs.
Incident Description
- The incident occurred in a billiard hall in Barili, Cebu, involving Esteban Paras, Alfonso Carvajal, and the defendant, Filemon Bayutas.
- Bayutas proposed a wager against Paras, which Paras found inappropriate due to their familial relationship.
- After a brief exchange, Bayutas struck Paras first on the nape of the neck with a piece of wood and then on the forehead, leading to Paras losing consciousness.
Medical Findings
- Dr. Cesar Mercader examined Paras and found contused wounds on the for