Wednesday, February 22, 2012

US vs. Bayutas

Facts: On the night of October 8, 1913, Esteban Paras and Alfonso Carvajal were playing a game of billiards when Filemon Bayutas, suggested laying a wager on Carvagal against Paras when they were about to commence a new one. The latter then told Bayutas not to do so, but Bayutas just answered by telling Paras to keep still and go on playing. Paras replied by saying “All right, as you wish; name the bet; that is my proposition.” At the very moment when Paras initiated the game on cue, Bayutas struck Paras with a piece hard wood about two inches in diameter a heavy blow on the nape of the neck and when the latter turned around to face his assailant, he received another blow on the forehead from the effects of which he fainted. 

The wounds required 58 days to heal, during which period he at first manifested symptoms of brain fever, a consequence of the habitual drinking of tuba. 

Issue: Whether or not, Filemon Bayutas incurred criminal liability. 

Held: Paragraph 1 of Article 4 of the Revised Penal Code states that criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that which was intended. From the facts aforestated, it results that the crime of serious physical injuries has been committed and that Filemon Bayutas incurred criminal liability. 

Although the wounds might have been cured sooner than 58 days had the offended party not been addicted to tuba drinking, this does not mitigate the liability of the accused. If Paras, owing to his physical condition and the state of his health, was not cured in a less number of days than that specified, Bayutas is responsible nevertheless for all the consequences of the injuries that resulted.

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