Case Summary (G.R. No. 169973)
Petitioner, Respondent, and Procedural Posture
The prosecution by the United States proceeded against Marasigan for wounds inflicted on Mendoza. The trial court found the facts in favor of the prosecution and rendered judgment against the defendant. The defendant appealed, asserting among other claims that he was entitled to a new trial to present medical testimony intended to alter the assessment of the injury’s permanence and to correct identification of which finger was disabled.
Key Dates
Factual incident: 23 January 1913, about 4:00 p.m.
Decision: (date provided in prompt) — the events and appeal arise from the trial court’s adjudication of the 1913 incident.
Applicable Law and Governing Framework
The decision turns on factual findings made by the trial court, the legal sufficiency of the evidence to support those findings, and the standards for granting a new trial based on proffered additional evidence. The court’s disposition rests on principles embodied in the governing criminal and procedural rules as applied in the decision: (1) appellate review of factual findings is deferential where the trial court’s findings are supported by the record; and (2) a new trial will not be granted on the basis of proffered additional evidence when that evidence would not materially change the legal consequences or where the proffered change is immaterial to the offense as established.
Facts Found by the Trial Court
Mendoza was examining his sugar crop when the accused and his wife summoned him. A verbal exchange ensued over a curved boundary line; when Mendoza resisted altering the line, Marasigan called Mendoza’s statement false, drew a knife, and struck at Mendoza. Mendoza was cut in the left hand while warding off the blow. A struggle followed in which Mendoza seized Marasigan, threw him down, and both wrestled over possession of the dagger. Marasigan’s wife removed the dagger from her husband’s hand but then intervened physically by seizing Mendoza by the neck and throwing him away. Marasigan subsequently struck Mendoza, knocking him senseless. Mendoza suffered three wounds (two in the chest and one in the left hand); the left-hand wound severed the extensor tendon of one finger. The wounds were treated and healed in seven days at a cost of approximately P45, but the middle finger of the left hand was rendered useless.
Appellant’s Account and Appellant’s Argument on Appeal
Marasigan offered a different version of events at trial; however, the trial court accepted the prosecution’s version and the evidence supports the court’s findings. On appeal, Marasigan sought a new trial on the ground that he could, if given another opportunity, present testimony from a physician, Gregorio Limjoco, that would (a) establish that the finger the court found useless was not necessarily permanently so because surgical intervention could restore function, and (b) show that it was the third finger (rather than the middle finger) that was disabled.
Court’s Review of Factual Findings and Standard of Appellate Review
The appellate court examined the record closely and found no reason to disturb the trial court’s factual findings. The court emphasized that the trial court’s factual determinations were supported by the evidence and therefore entitled to deference on appeal.
Court’s Analysis of the Motion for a New Trial Based on Additional Medical Evidence
The court treated the appellant’s proffer of new medical testimony as insufficient to warrant a new trial for two principal reasons:
- Materiality and identity of the injured digit: It is immaterial to the criminal liability and to the legal consequences of the act which particular finger was rendered useless. All parties concurred that one
Case Syllabus (G.R. No. 169973)
Case Citation and Decision
- Reporter and page: 27 Phil. 504.
- G.R. No.: 9426.
- Decision date: August 15, 1914.
- Opinion authored by: Justice Moreland (D E C I S I O N MORELAND, J.).
- Parties: The United States, plaintiff and appellee, versus Filomeno Marasigan, defendant and appellant.
- Final disposition: Judgment appealed from is affirmed, with costs against the appellant.
Geographic and Temporal Setting
- Date and time of the incident: About 4 o'clock in the afternoon of January 23, 1913.
- Place of the incident: On the sugar crop grounds of Francisco Mendoza, located upon his lands in the barrio of Irucan (now called Calayan), municipality of Taal, Batangas Province.
Principal Actors
- Victim: Francisco Mendoza, engaged in examining his sugar crop at the time of the incident.
- Accused / Appellant: Filomeno Marasigan.
- Accused’s spouse: The wife of Filomeno Marasigan (unnamed in the source).
- Proposed medical witness named by appellant: Physician Gregorio Limjoco.
Factual Background
- Mendoza was examining his sugar crop on his land when the accused and the accused's wife asked him to approach them.
- Upon approach, the accused commented on the division line between their lands, asking: "Why is this line curved? Let us make it straight."
- Mendoza responded by warning that making the line straight would place certain logs and trees on the accused's land.
- The accused asserted that the logs were placed simply to mark his land.
- Mendoza questioned why the accused was not satisfied with the existing line as it was when the parties took possession of their respective lands.
- The accused replied: "This is false," and then drew his knife and struck at Mendoza.
Sequence of the Physical Altercation
- Mendoza attempted to ward off the blow and was cut in the left hand.
- The accused continued the attack; Mendoza seized the accused by the neck and body and threw him down.
- While both men were on the ground, the accused attempted further blows with his dagger.
- Mendoza seized the hand holding the dagger and attempted to loosen his hold while they fought for possession of the knife.
- The accused's wife intervened: she took the dagger from her husband and threw it aside.
- The wife then seized Mendoza by the neck and threw him