Roberto V. Navarrete v. People

Summary

Roberto V. Navarrete was convicted of serious physical injuries for punching Bernardo Maralit in the left eye during a heated argument. The Supreme Court affirmed the conviction, ruling that the injury constituting an 'illness' requiring more than 30 days healing period satisfies Article 263(4) of the Revised Penal Code, regardless of the victim's ability to work during recovery. The Court applied a mitigating circumstance, finding Navarrete had no intention to commit such grave wrong, as he merely parried blows and threw only one punch in self-defense. The sentence was modified to 4 months and 1 day of arresto mayor with option for community service under RA 11362. The damages award of P194,825.15 actual damages and P50,000.00 moral damages with 6% annual interest was affirmed. The case clarifies that 'illness' under the serious physical injuries provision focuses on healing period rather than work incapacity.