The People of the Philippine Islands v. Alipio Balubar

Summary

This landmark 1934 Supreme Court case established that the loss of front teeth constitutes permanent disfigurement under the Revised Penal Code's physical injuries provisions. Defendant Balubar struck victim Pizarro with a truck crank, breaking four front teeth and causing facial disfigurement. The Supreme Court, citing extensive Spanish jurisprudence, held that visible tooth loss constitutes 'lesiones graves' under Article 263(3), rejecting the defendant's version that injuries resulted from an accidental fall. The Court emphasized that artificial teeth cannot repair the legal injury, as the disfigurement from natural tooth loss is permanent regardless of potential cosmetic remedies. The decision modified the sentence, removing nocturnity as an aggravating factor while affirming that front teeth qualify as 'members of the body' under the penal code, establishing important precedent for physical injury cases involving dental damage.