Physical Injuries in the Philippines (Revised Penal Code)

Generated: 2026-07-03 | Intellegal Deep Research

Answer Summary

The Revised Penal Code (RPC) classifies physical injuries into three degrees — serious, less serious, and slight — based on the gravity of harm and the resulting period of incapacity for labor or medical attendance. Serious physical injuries (Article 263) involve grave consequences such as loss of a body part, permanent deformity, insanity, or illness/incapacity for more than 30 days; less serious physical injuries (Article 265) arise when the injury incapacitates the victim for 10 to 30 days or requires medical attendance for the same period; slight physical injuries (Article 266) cover incapacity from 1 to 9 days, mere physical pain without incapacity, or maltreatment by deed without injury. Where the assault could constitute attempted or frustrated homicide, the dispositive element is intent to kill (animus interficendi). If the prosecution proves beyond reasonable doubt that the offender intended to cause death, the crime is classified against life; if intent to kill is not established, the offender is liable only for the resulting physical injuries, even if the wounds were inflicted with a weapon.

The controlling statutory provisions are Articles 263, 265, and 266 of the Revised Penal Code, as amended by Republic Act No. 10951 (effective 2017), which increased the fines imposable for less serious and slight physical injuries. The Supreme Court has consistently held that the distinction between physical injuries and attempted/frustrated homicide depends on the element of intent to kill. Leading decisions include Peñaranda v. People, G.R. No. 214426 (2021), which reiterated that when intent to kill is not proven, the conviction must be for the specific physical injury caused; People v. Mondragon, G.R. No. L-17666 (1966), which emphasized that intent to kill must be proved by clear and convincing evidence; and Ruego v. People, G.R. No. 226745 (2021), which clarified that the loss of teeth does not per se constitute serious physical injuries unless visible deformity is established at trial, effectively superseding the strict rule in People v. Balubar, G.R. No. 40940 (1934).

For serious physical injuries under Article 263, the penalty ranges from arresto mayor to prision mayor depending on the specific harm, with higher penalties when the victim is a parent, ascendant, guardian, or when attended by circumstances enumerated under Article 248. Less serious physical injuries are punishable by arresto mayor, with an additional fine up to ₱50,000 if inflicted with manifest intent to insult or under ignominy. Slight physical injuries carry the penalty of arresto menor or fine, depending on the degree of incapacity. The gravity of injuries is determined by medical evidence of the actual healing period, not the prescribed leave or mere allegation. Absent a medical certificate proving the specific duration of incapacity, the crime defaults to slight physical injuries under Article 266(2) or (3).

Common failure points include: (a) the prosecution’s inability to present medical evidence specifying the exact period of incapacity, as seen in Salinas v. People, G.R. No. 263112 (2023), where the absence of proof on duration led to a conviction for slight physical injuries instead of a graver classification; (b) relying solely on the nature of the weapon without proof of intent to kill, which often results in the downgrading of an attempted homicide charge to physical injuries, as in U.S. v. Barnes, G.R. No. L-3129 (1907) and many subsequent cases; and (c) the assumption that tooth loss automatically constitutes serious physical injuries, a view that has been rejected by the modern doctrine in Ruego requiring a showing of visible deformity after medical intervention.

Since the enactment of RA 10951, the fines in the RPC have been adjusted to current values, and Republic Act No. 11362 (Community Service Act) now allows courts to impose community service in lieu of imprisonment for penalties of arresto menor and arresto mayor. Based on comprehensive database and web research, no rulings from 2024-2026 were found on this topic. The most recent authority is People v. Pilen, G.R. No. 254875 (2023).

Section I — Issue Overview

1. What are the statutory elements and penalties for serious, less serious, and slight physical injuries under the Revised Penal Code? This sub-issue identifies the specific acts, resulting harm, and corresponding penal sanctions for each degree of physical injury, which governs charging decisions and plea bargaining.

2. How is the gravity of physical injuries determined under Philippine law? This sub-issue addresses the criteria — duration of incapacity, medical attendance, permanent effects — used by courts to classify injuries, and the evidentiary requirements to prove such classification.

3. How do the offenses of serious, less serious, and slight physical injuries relate to attempted or frustrated homicide? This sub-issue examines the crucial boundary between crimes against persons (physical injuries) and crimes against life (attempted/frustrated homicide or murder), focusing on the element of intent to kill and the circumstances that prove or negate such intent.

Section II — Legal Analysis

Issue 1: Elements and Penalties for Serious, Less Serious, and Slight Physical Injuries

Applicable Laws & Issuances

The classification and penal sanctions for physical injuries are primarily governed by Articles 263, 265, and 266 of the Revised Penal Code, as amended by Republic Act No. 10951. The relevant provisions are:

• Article 263. Serious Physical Injuries — Any person who shall wound, beat, or assault another shall be guilty of serious physical injuries if the act causes: (1) loss of a body part, insanity, imbecility, impotence, or blindness; (2) loss of use of speech, hearing, smell, an eye, hand, foot, arm, or leg, or incapacity for the victim’s habitual work; (3) deformity or loss of any body part; (4) illness or incapacity for labor for more than 30 days (whether or not the victim can still work).[1] The penalty ranges from arresto mayor (for incapacity >30 days) to prision mayor (for permanent loss of body parts), and may be increased to reclusion temporal if the victim is a relative under Article 246 or if attended by circumstances enumerated in Article 248 (murder).

• Article 265. Less Serious Physical Injuries — Applies when the injuries do not fall under Article 263 but incapacitate the victim for labor for 10 days or more, or require medical assistance for the same period. Penalty: arresto mayor. If inflicted with manifest intent to insult or offend, or under circumstances adding ignominy, a fine not exceeding ₱50,000 is added. If committed against parents, ascendants, guardians, curators, teachers, or persons in authority, the penalty is prision correccional in its minimum and medium periods.[2]

• Article 266. Slight Physical Injuries and Maltreatment — Punished: (1) by arresto mayor when incapacitating the victim for labor from 1 to 9 days, or requiring medical attendance during the same period; (2) by arresto menor or a fine not exceeding ₱40,000 and censure when the physical injuries do not prevent the victim from engaging in habitual work nor require medical assistance; and (3) by arresto menor in its minimum period or a fine not exceeding ₱5,000 for ill-treatment by deed without causing any injury.[3]

The fines prescribed in Articles 265 and 266 were adjusted by Republic Act No. 10951, which took effect in 2017.[4] The community service alternative under Republic Act No. 11362 and its implementing guidelines (A.M. No. 20-06-14-SC) may be applied for penalties of arresto menor and arresto mayor.[5]

Case Law Analysis

Ronilo Velasco y De Leon v. People, G.R. No. 255490 — 30 June 2021

Focus of Dispute: Whether the injuries on the victim’s head, which required medical attendance for not less than 31 days, constituted serious physical injuries under Article 263, paragraph 4.

Facts: Petitioner hit the victim with a bottle and punched him during an altercation. A Medico-Legal Report established the head injuries required medical attendance for not less than 31 days. Both the trial court and the Court of Appeals convicted petitioner of serious physical injuries.

Disposition: The Supreme Court affirmed the conviction and imposed an indeterminate penalty of 3 months and 1 day of arresto mayor as minimum, to 1 year and 8 months of prision correccional as maximum, plus damages.

Ratio Decidendi: The Court held that when the injury causes an illness or incapacity for labor that lasts more than 30 days, the proper classification is serious physical injuries under Article 263(4), regardless of whether the victim could still work during that period. The medical certificate proving the required period of medical attendance was sufficient to prove the gravity.

Evidence Evaluated: The Medico-Legal Report showing “not less than 31 days” of medical attendance was crucial. The defense did not controvert this evidence.

Roberto V. Navarrete v. People, G.R. No. 253340 — 03 May 2021

Focus of Dispute: Whether a punch to the left eye that caused an injury requiring more than 30 days to heal constituted serious physical injuries under Article 263(4).

Facts: Petitioner punched Bernardo Maralit in the left eye during an argument, causing an injury that necessitated a healing period exceeding 30 days. Petitioner claimed he merely parried blows.

Disposition: The Supreme Court affirmed the conviction for serious physical injuries but applied the mitigating circumstance that the offender had no intention to commit so grave a wrong as that caused, modifying the penalty to 4 months and 1 day of arresto mayor with the option for community service, and affirming damages.

Ratio Decidendi: The Court clarified that “illness” under paragraph 4 of Article 263 is determined by the healing period, not the victim’s ability to work. Proof of a healing period exceeding 30 days is sufficient to bring the offense under serious physical injuries, even if the victim was not incapacitated from labor for the entire duration.

Evidence Evaluated: Medical evidence of the healing period was decisive. The Court gave weight to the actual medical findings.

Anna Liza V. Salinas v. People, G.R. No. 263112 — 18 January 2023

Focus of Dispute: Whether the injuries caused by poking the victim with a spoon constituted slight physical injuries under Article 266(1) (with incapacity) or Article 266(2) (without proof of incapacity).

Facts: Petitioner poked Rogelio Dela Cruz with a spoon, causing injuries to his lips and forehead. The trial court and Court of Appeals convicted her under Article 266(1).

Disposition: The Supreme Court modified the conviction to Article 266(2) and retained the penalty of 20 days arresto menor.

Ratio Decidendi: The prosecution failed to present sufficient evidence of the duration of incapacity or medical attendance required under paragraph 1. Where the evidence does not establish the specific period of incapacity, the offense is properly classified as the lesser variant under Article 266(2), which merely requires physical injuries that do not prevent the victim from working nor require medical assistance.

Evidence Evaluated: Absence of a medical certificate detailing the period of recovery or medical attendance was fatal to the graver charge.

Doctrinal Synthesis

The current legal framework, as clarified by recent jurisprudence, employs a strict durational standard for physical injuries. The period of incapacity for labor or medical attendance, as proven by competent medical evidence, primarily determines whether injuries are serious (>30 days), less serious (10 to 30 days), or slight (1 to 9 days). When no such period is proven, the default is slight physical injuries under the modes that do not require proof of incapacity. The penalty escalates based on the permanence of the harm (loss of body part, deformity) or the relationship of the victim. RA 10951 has updated the fine amounts, and RA 11362 provides a humane alternative for short imprisonments.

Recent Developments

Recent rulings such as Salinas (2023) reinforce the strict evidentiary requirement for incapacity. No legislative amendments directly affecting the elements of the three degrees of physical injuries have been enacted since RA 10951. No decisions from 2024-2026 were identified on this specific sub-issue.

Issue 2: Determination of Gravity of Physical Injuries

Applicable Laws & Issuances

The same statutory provisions govern gravity determination:

• Article 263 lists specific consequences: loss of a body part, insanity, impotence, blindness, loss of use, deformity, illness/incapacity >30 days.[1]
• Article 265 covers incapacity/medical attendance from 10 to 30 days.[2]
• Article 266 covers incapacity/medical attendance from 1 to 9 days, and lesser forms.[3]

Additionally, Section 3, Rule 129 of the Rules of Court (judicial notice) and ordinary rules of evidence require that medical findings be proven through expert testimony or duly authenticated medical certificates.

Case Law Analysis

Elpedio Ruego v. People, G.R. No. 226745 — 03 May 2021

Focus of Dispute: Whether a fractured tooth that was medically repaired without visible disfigurement constitutes serious physical injuries under Article 263(3) (deformity) or a lesser offense.

Facts: Ruego punched Anthony Calubiran, fracturing his front tooth. The tooth was later restored and showed no visible deformity at trial. The trial court convicted Ruego of serious physical injuries based on the 1934 doctrine in Balubar that loss of front teeth is per se serious.

Disposition: The Supreme Court modified the conviction to slight physical injuries.

Ratio Decidendi: The Court held that for tooth loss to constitute serious physical injuries, there must be a factual determination of visible deformity at trial. Advances in dental science allow teeth to be effectively restored; thus, the strict rule in Balubar is no longer controlling. The Court stated:

“Deformity means ‘visible ugliness, permanent and visible physical abnormality’ that cannot be repaired by nature… where medical intervention has eliminated any visible disfigurement, the injury may be classified as slight physical injuries under Article 266.”

Evidence Evaluated: The prosecution did not present evidence of visible deformity at the time of trial. The tooth had been repaired. No permanent visible disfigurement remained.

Precedential Status: This decision effectively supersedes the Balubar doctrine and establishes the current rule on tooth loss.

The United States v. Ciriaco Herrera, G.R. No. 4960 — 17 July 1909

Focus of Dispute: Whether wounds requiring medical attendance for more than eight days but not causing work incapacity constituted less serious physical injuries or a mere misdemeanor.

Facts: Herrera wounded Silvestre Bautista with a penknife; the wound required medical attendance for more than eight days. The defense argued the injury should be a misdemeanor because the victim could still work.

Disposition: The Supreme Court En Banc affirmed the conviction for lesiones menos graves.

Ratio Decidendi: The Court held that under then-Article 418 of the Penal Code, medical attendance of more than eight days was sufficient to constitute less serious physical injuries, regardless of whether the victim was incapacitated for labor. This underscores that the period of medical attendance independently establishes the degree of injury.

Evidence Evaluated: Medical testimony on the duration of medical attendance was determinative.

The United States v. Agapito Lazada, G.R. No. L-3997 — 08 January 1908

Focus of Dispute: Proper classification of physical injuries when the injuries were trivial and caused no incapacity.

Facts: Lazada assaulted Pedro Sopengco, causing only bruises. No medical attention was needed, and the victim suffered no incapacity beyond seven days.

Disposition: The Supreme Court reclassified the offense from lesiones menos graves to a simple misdemeanor.

Ratio Decidendi: When the injuries are trivial and neither medical attendance nor incapacity is proven, the act is not a crime of physical injuries within the meaning of the code but a mere misdemeanor (now under Article 266(3) as slight physical injuries/maltreatment). Actual proof of injury severity is essential for classification.

Doctrinal Synthesis

Gravity of physical injuries is a question of fact, proven primarily through medical evidence. The period of medical attendance or incapacity is the core benchmark. The longer the period, the graver the offense. Permanent consequences (deformity, loss of a body part) automatically elevate the injury to serious. However, deformity must be objectively visible and not curable by ordinary medical means; the Ruego case modernized this by requiring a visible deformity at trial. In the absence of medical proof of the period of incapacity, courts must default to slight physical injuries under Article 266(2) or (3). The standard is actual, not prescribed, incapacity.

Recent Developments

The Ruego ruling (2021) is the most significant recent development on gravity. It departs from Balubar (1934) and aligns with People v. Oh Suilay, G.R. No. 40699 (1934), which had categorized tooth loss as less serious physical injuries. No subsequent Supreme Court decision from 2024-2026 has altered this standard.

Issue 3: Relationship of Physical Injuries to Attempted/Frustrated Homicide

Applicable Laws & Issuances

Article 6 of the Revised Penal Code defines attempted and frustrated felonies. An attempt occurs when the offender commences the commission of a felony directly by overt acts but does not perform all the acts of execution by reason of some cause or accident other than spontaneous desistance. A frustrated felony occurs when the offender performs all the acts of execution that would produce the felony as a consequence but the felony is not produced by causes independent of the offender’s will.

The crime of homicide is defined in Article 249. Attempted or frustrated homicide requires that all elements be present, including intent to kill — the specific intent to cause death. Where such intent is not proven, the crime committed is physical injuries, regardless of the nature of the weapon used.

Section 4, Rule 120 of the Rules of Criminal Procedure provides that an accused may be convicted of a lesser offense necessarily included in the charged offense. Physical injuries may thus be a lesser included offense in an information for attempted/frustrated homicide or murder.

Article 48 of the Revised Penal Code (complex crimes) may apply when a single act results in both homicide/physical injuries, but not where the offense is specifically punished under a single provision.

Case Law Analysis

Isidoro Mondragon v. People, G.R. No. L-17666 — 30 June 1966

Focus of Dispute: Whether the petitioner had intent to kill, essential for attempted homicide, or only committed less serious physical injuries.

Facts: During a quarrel over water supply, petitioner first threw fist blows, then drew a bolo and inflicted six incised wounds. The victim fought back, and petitioner retreated. The wounds healed in 20-25 days and were “not necessarily fatal.”

Disposition: The Supreme Court modified the conviction from attempted homicide to less serious physical injuries.

Ratio Decidendi: The Court declared:

“The intent to kill being an essential element of the offense of frustrated or attempted homicide, said element must be proved by clear and convincing evidence… The inference of intent to kill should not be drawn in the absence of circumstances sufficient to prove such intent beyond reasonable doubt.” Three factors negated intent: the initial assault with fists, the wounds’ slight nature, and petitioner’s retreat when the victim fought back. The crime was propertly classified as less serious physical injuries under Article 265 because the wounds healed in less than 30 days.

Evidence Evaluated: The medical certificate showing healing within 20-25 days and the nature of the wounds were decisive. The Court rejected the inference of intent from a statement made years later.

The United States v. Fabiana Manlalang, G.R. No. 2642 — 31 July 1906

Focus of Dispute: Whether the pocketknife attack constituted attempted homicide or physical injuries.

Facts: Defendant inflicted two wounds with a pocketknife — one on the upper arm, one on the left side. The wounds were long but not deep, healed in 13 days. After stabbing twice, the defendant threw away the knife and remained quietly beside the victim.

Disposition: The Supreme Court reversed the conviction for attempted homicide and convicted her of lesiones (less serious physical injuries).

Ratio Decidendi:

“It is a necessary ingredient of the crime of attempted homicide that the aggressor, in committing the assault, had the intention to kill.” The absence of motive, the mild wounds, and the spontaneous cessation of the assault negated intent.

Evidence Evaluated: Victim’s own testimony that there was no prior ill feeling and that the defendant stopped on her own was critical.

Rolen Peñaranda v. People, G.R. No. 214426 — 02 December 2021 (Web Source)

Focus of Dispute: Whether the attack with weapons during a fare dispute constituted attempted murder or serious physical injuries due to lack of intent to kill.

Facts: The petitioner, armed with a kitchen knife and a fan knife, attacked the victim after a fare dispute. The trial court convicted him of attempted murder, but on appeal, the Supreme Court re-examined the evidence of intent to kill.

Disposition: The Supreme Court modified the conviction to serious physical injuries under Article 263, paragraph 4.

Ratio Decidendi: The Court distinguished between attempted/frustrated homicide/murder and physical injuries using the factors of whether the injury was fatal and whether there was intent to kill. Intent to kill is deduced from: (1) means used; (2) nature, location, and number of wounds; (3) conduct of the accused; and (4) circumstances/motive. Where these factors do not overwhelmingly prove intent to kill, the crime is physical injuries. Further, if the offender’s acts were not stopped by spontaneous desistance but the lethal intent is absent, there is no attempt. Physical injuries is a lesser included offense that may be proved.

Precedential Status: This 2021 ruling reaffirms the Mondragon line and is the Court’s current leading pronouncement on the subject.

People v. Pilen, G.R. No. 254875 — 13 February 2023 (Web Source)

Focus of Dispute: Reiterated the distinction between attempted/frustrated homicide and physical injuries.

Disposition/Ratio: The Supreme Court, citing Peñaranda, emphasized that intent to kill must be proven beyond reasonable doubt. If not, the accused can only be convicted of the specific physical injury inflicted. This case confirms the stability of the doctrine.

Doctrinal Synthesis

The relationship between physical injuries and attempted/frustrated homicide is governed by the element of intent to kill. Physical injuries are not merely lesser degrees of homicide; they are separate offenses that come into play when the animus interficendi is lacking. The prosecution must prove intent to kill with the same degree of certainty as any other element. The four-factor test — weapon used, nature/location/number of wounds, conduct of the accused, and motive/circumstances — is the standard for evaluating intent. Where wounds are non-fatal, the accused desists, or the motive is trivial, the Supreme Court has consistently held that the offense is physical injuries, not an attempt or frustration of homicide. Physical injuries may also be a proper verdict as a lesser included offense under a charge for attempted or frustrated homicide.

Recent Developments

Peñaranda (2021) and Pilen (2023) are the most recent authoritative decisions on the distinction. They do not alter the long-standing Mondragon doctrine but reaffirm it. No rulings from 2024-2026 were found on this specific issue.

Analysis

The user’s inquiry seeks a comprehensive understanding of the three-tier system of physical injuries under the RPC and its interface with crimes against life. The statutory framework — Articles 263, 265, and 266 — creates a bright-line hierarchy based on the gravity of harm and, in cases of doubt, on the availability of medical evidence. The jurisprudence demonstrates that courts will not presume the higher degree; the prosecution bears the burden of proving the qualifying facts. When intent to kill is not proven, the more severe crime of attempted or frustrated homicide cannot stand; the accused’s liability is limited to the physical injury actually caused. This principle is applied uniformly whether the weapon used was a knife, bolo, or fists. Consequently, for practicing attorneys, the strategic approach must focus on: (a) in prosecution, documenting the exact period of incapacity and securing a clear medical certificate; (b) in defense, scrutinizing the evidence of intent to kill and challenging any presumption of homicidal purpose.

Section III — Action Plan & Evidence Guide

Recommended Strategy: When handling a potential physical injuries or homicide case, counsel must first ascertain the degree of injury through competent medical documentation and then evaluate the quality of evidence regarding the accused’s intent, as this will determine whether the case should be pursued as a crime against persons or a crime against life. Plea bargaining and downgrading of charges are directly affected by these classifications.

Action Steps

1. Secure medical evidence immediately — Obtain a detailed medico-legal certificate stating the nature of wounds, period of medical attendance, and duration of incapacity (actual, not merely prescribed). This is critical for classifying the injury under the appropriate Article.
2. Preserve evidence of intent — Collect witness accounts, CCTV footage, weapons, and any statements showing motive or conduct before, during, and after the incident. Use the Peñaranda factors: means used, nature/location/number of wounds, conduct, and circumstances.
3. Evaluate the charge — If charged with attempted/frustrated homicide, assess whether the medical evidence shows the wounds were fatal or if the conduct indicates desistance. If intent to kill is weak, move for a dismissal or reduction to physical injuries, or advise a plea to a lesser offense.
4. Consider multiple offenses — Under the doctrine in Fontanilla, injuries to multiple victims may constitute separate crimes. Each victim’s injury must be independently classified.
5. Explore community service — If the expected penalty is arresto menor or arresto mayor, apply for community service under RA 11362 after finality of judgment.

Evidence Checklist

• Medico-Legal Report — proves the nature, period of healing, and permanent effects; secured from the attending physician or PNP Crime Laboratory.
• Medical Certificate of Incapacity — establishes the exact number of days the victim was unable to perform habitual work; from the treating hospital.
• Photographs of injuries (before and after treatment) — demonstrate visible deformity or the absence thereof, as required by Ruego.
• Sworn statements of eyewitnesses — describe the weapon, manner of attack, and whether the accused pursued or desisted.
• Accused’s extrajudicial admissions or social media posts — may reveal motive or intent.
• Police blotter entries — contain initial accounts and may corroborate or contradict later testimony.

⚠️ This is AI-generated legal research for reference only. It does not constitute legal advice. Consult a licensed Philippine attorney before making important legal decisions.

References

Legislation & Regulatory Issuances

• The Penal Code (-)
• Serious physical injuries, A263 Revised Penal Code — legalresource.ph
• Less serious physical injuries, A265 Revised Penal Code — legalresource.ph
• G.R. No. 214426 - Lawphil (Peñaranda v. People) — Rolen Peñaranda v. People
• G.R. No. 254875 - Lawphil (People v. Pilen) — People v. Jonie Sabandal Pilen

Case Law

• Isidoro Mondragon v. People, G.R. No. L-17666 (30 June 1966)
• The United States v. Fabiana Manlalang, G.R. No. 2642 (31 July 1906)
• The United States v. W.B. Barnes, G.R. No. L-3129 (15 March 1907)
• The United States v. Saturnino Trinidad, G.R. No. 1851 (23 January 1905)
• People v. Juan Montes et al., G.R. No. 30686 (12 August 1929)
• Ladislao Espinosa v. People, G.R. No. 181071 (15 March 2010)
• Ronilo Velasco y De Leon v. People, G.R. No. 255490 (30 June 2021)
• Roberto V. Navarrete v. People, G.R. No. 253340 (03 May 2021)
• Anna Liza V. Salinas v. People, G.R. No. 263112 (18 January 2023)
• Russel Salvador Peralta and Edmund Estrada v. People, G.R. No. 246992 (14 August 2019)
• The United States v. Lauro Fontanilla, G.R. No. L-12916 (16 December 1917)
• Edgar Reyes v. People, G.R. No. 243419 (18 March 2019)
• Elpedio Ruego v. People, G.R. No. 226745 (03 May 2021)
• The United States v. Ciriaco Herrera, G.R. No. 4960 (17 July 1909)
• The United States v. Agapito Lazada, G.R. No. L-3997 (08 January 1908)
• The People of the Philippine Islands v. Alipio Balubar, G.R. No. 40940 (09 October 1934)
• Rolen Peñaranda v. People, G.R. No. 214426 (02 December 2021)
• People v. Pilen, G.R. No. 254875 (13 February 2023)