- Petitioner
- People
- Respondent
- Miguel Lasala
- Citation
- G.R. No. L-12141
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Bautista Angelo, J.
- 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.