Case Summary (G.R. No. L-6503)
Legal Definition of "Lesiones" and Applicability of Penal Code
- The act of inflicting injuries (lesiones) through the use of corrosive substances, such as throwing sulphuric acid, is not explicitly defined as an offense under Article 416 of the Penal Code.
- Article 416 outlines specific offenses related to physical injuries, but the method of using chemicals or poisons does not fall within its purview.
Aggravating Circumstances and Treachery
- The trial court considered the aggravating circumstance of nocturnity in conjunction with the finding of treachery (alevosia) in the commission of the crime.
- It is established that nocturnity, when already factored into the determination of treachery, should not be treated as a separate aggravating circumstance for sentencing purposes.
Factual Findings and Trial Court's Decision
- The evidence presented at trial confirmed that the defendant threw sulphuric acid at the victim, causing significant injuries that resulted in the victim's illness lasting over thirty days.
- The attack was characterized as treacherous, occurring at night and from a concealed position, leaving the victim unprepared for the assault.
Sentencing and Legal Implications
- The trial court convicted the defendant of lesiones under subsection 4 of Article 416, in conjunction with Article 417, and imposed a sentence of 1 year and 1 day of imprisonment, considering nocturnity as an aggravating factor.
- However, the presence of treachery should have led to the application of the special penalty outlined in the last paragraph of Article 416, which prescribes a penalty of prision correccional in its minimum and medium degree.