- Petitioner
- People
- Respondent
- Miguel Lasala
- Citation
- G.R. No. L-12141
- Court
- Supreme Court
- Decided
- January 30, 1962
Whether the acts constitute a complex crime of serious slander by deed with less serious physical injuries, or a single offense of less serious…
Summary
The Supreme Court affirmed the trial court's order requiring the prosecution to amend the information from a complex crime of serious slander by deed with less serious physical injuries to a single offense under Article 265, paragraph 2 of the Revised Penal Code. The Court held that when an act inflicts less serious physical injuries with manifest intent to insult or under circumstances adding ignominy, it should be prosecuted under the specific provision of Article 265, paragraph 2, rather than as a complex crime under Article 48. The case establishes that specific provisions in the Penal Code take precedence over the general complex crime rule when the acts fall squarely within the specific provision's coverage. The assault on a municipal mayor in a public cockpit clearly demonstrated the manifest intent to insult and add ignominy to the offense.
Focus of dispute
Whether the acts constitute a complex crime of serious slander by deed with less serious physical injuries, or a single offense of less serious physical injuries with manifest intent to insult under Article 265, paragraph 2 of the Revised Penal Code
Legal facts
Miguel Lasala was accused of assaulting Mayor Wenceslao Andanar with fistic blows in a public cockpit where many people were present on September 11, 1956, in Surigao. The assault caused bruises and contusions requiring 14 days medical treatment and incapacitating the victim for 12 days from his customary labors. The prosecution initially charged this as a complex crime of serious slander by deed with less serious physical injuries, but the defense filed a motion to quash arguing it constituted only a single offense under Article 265, paragraph 2 of the Revised Penal Code.
Judgement and reasoning
Supreme Court (SC): Affirmed the trial court order, holding that Article 265, paragraph 2 specifically covers acts of less serious physical injuries committed with manifest intent to insult or under circumstances adding ignominy to the offense. The Court ruled that this specific provision is an exception to the complex crime rule in Article 48, and since the assault was committed in a public cockpit against an incumbent municipal mayor, it falls under the specific provision rather than constituting a complex crime.
Trial court: Granted the motion to quash, holding that the crime committed is less serious physical injuries with manifest intent to insult and offend under Article 265, paragraph 2 of the Revised Penal Code, not a complex crime. The court reasoned that complex crimes only exist where the Code has no specific provision penalizing the same acts with a definite specific penalty.