Elpedio Ruego v. People

Summary

This Supreme Court case involved determining whether a fractured tooth constitutes serious physical injuries under the Revised Penal Code. Elpedio Ruego punched Anthony Calubiran during a street altercation, fracturing Calubiran's front tooth. Lower courts convicted Ruego of serious physical injuries based on the 1934 People v. Balubar precedent. However, the Supreme Court modified the conviction to slight physical injuries, establishing that for tooth loss to constitute serious physical injury, there must be factual determination of visible deformity at trial. Since Calubiran's tooth was medically repaired with no visible disfigurement, the Court reduced the penalty while acknowledging advances in dental science that render the Balubar doctrine obsolete in cases where teeth can be effectively restored.