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    Enrile v. Manalastas

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    adee
    1) The petitioners claimed that the complaints of less serious physical injuries should be dismissed because the complainants did not present proof that they received over 10 days of medical attention. 2) However, the complaints stated that the victims' injuries would require 10-15 days of medical attendance and incapacitate them from work for the same period. 3) The Supreme Court ruled that the complaints sufficiently established the elements of less serious physical injuries under the Revised Penal Code by alleging that the injuries incapacitated the victims for over 10 days or required over 10 days of medical assistance. Medical certificates only need to be presented at trial, not during the preliminary investigation. Therefore, the petition was denied.

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    Enrile v. Manalastas

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    adee
    589 views2 pages
    1) The petitioners claimed that the complaints of less serious physical injuries should be dismissed because the complainants did not present proof that they received over 10 days of medical attention. 2) However, the complaints stated that the victims' injuries would require 10-15 days of medical attendance and incapacitate them from work for the same period. 3) The Supreme Court ruled that the complaints sufficiently established the elements of less serious physical injuries under the Revised Penal Code by alleging that the injuries incapacitated the victims for over 10 days or required over 10 days of medical assistance. Medical certificates only need to be presented at trial, not during the preliminary investigation. Therefore, the petition was denied.

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    29. Enrile v. Manalastas

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    1) The petitioners claimed that the complaints of less serious physical injuries should be dismissed because the complainants did not present proof that they received over 10 days of medical attention. 2) However, the complaints stated that the victims' injuries would require 10-15 days of medical attendance and incapacitate them from work for the same period. 3) The Supreme Court ruled that the complaints sufficiently established the elements of less serious physical injuries under the Revised Penal Code by alleging that the injuries incapacitated the victims for over 10 days or required over 10 days of medical assistance. Medical certificates only need to be presented at trial, not during the preliminary investigation. Therefore, the petition was denied.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    589 views2 pages

    Enrile v. Manalastas

    Uploaded by

    adee
    1) The petitioners claimed that the complaints of less serious physical injuries should be dismissed because the complainants did not present proof that they received over 10 days of medical attention. 2) However, the complaints stated that the victims' injuries would require 10-15 days of medical attendance and incapacitate them from work for the same period. 3) The Supreme Court ruled that the complaints sufficiently established the elements of less serious physical injuries under the Revised Penal Code by alleging that the injuries incapacitated the victims for over 10 days or required over 10 days of medical assistance. Medical certificates only need to be presented at trial, not during the preliminary investigation. Therefore, the petition was denied.

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    VIOVICENTE, DANIELLE H.

    SECTION 6, RULE 110


    ENRILE V. MANALASTAS

    OCTOBER 22, 2014 G.R. NO. 166414 BERSAMIN, J.

    RECIT READY SYNOPSIS


    In this case, petitioners aver that subject complainants had not presented proof of their having been
    given medical attention lasting 10 days or longer, thereby rendering their charges of less serious physical
    injuries dismissible.

    The complaints here involved includes the following information:


    1. “…assault and strike the face of one JOSEFINA GUINTO MORAÑO, thereby inflicting upon his
    (sic) physical injuries that will require a period of 10 to 12 days barring healing and will
    incapacitate his customary labor for the same period of time attached Medical Certificate (sic).”
    2. “…assault and right and give hitting her head against pavement of one PERLA BELTRAN
    MORAÑO inflicting the latter physical injuries and will require Medical Attendance for a period of
    12 to 15 days barring unforeseen complication as per Medical Certificate hereto attached.”

    W/N the complaint sufficiently provides for the elements of herein alleged crime of less serious physical
    injuries.

    YES. According to Section 6, Rule 110 of the Rules of Court, the complaint or information is sufficient
    if it, among other things, states the acts or omissions complained of as constituting the offense. The
    complaint includes the elements of less serious physical injuries. Medical certificate might be necessary
    upon trial, but not during preliminary investigation. Petition denied.
    Relevant Provisions / Concept / Doctrines
    Fundamental test in determining the sufficiency of the averments in a complaint or information is whether
    the facts alleged therein, if hypothetically admitted, constitute the elements of the offense. To meet the
    test of sufficiency it is necessary to refer to the law defining the offense charged.
    FACTS
    In this case, petitioners aver that subject complainants had not presented proof of their having been
    given medical attention lasting 10 days or longer, thereby rendering their charges of less serious physical
    injuries dismissible.

    The complaints here involved includes the following information:


    3. “…assault and strike the face of one JOSEFINA GUINTO MORAÑO, thereby inflicting upon his
    (sic) physical injuries that will require a period of 10 to 12 days barring healing and will
    incapacitate his customary labor for the same period of time attached Medical Certificate (sic).”
    4. “…assault and right and give hitting her head against pavement of one PERLA BELTRAN
    MORAÑO inflicting the latter physical injuries and will require Medical Attendance for a period of
    12 to 15 days barring unforeseen complication as per Medical Certificate hereto attached.”
    ISSUE
    W/N the complaint sufficiently provides for the elements of herein alleged crime of less serious physical
    injuries.
    RULING
    YES.

    According to Section 6, Rule 110 of the Rules of Court, the complaint or information is sufficient if it
    states the names of the accused; the designation of the offense given by the statute; the acts or
    omissions complained of as constituting the offense; the name of the offended party; the approximate
    date of the commission of the offense; and the place where the offense was committed. The fundamental
    test in determining the sufficiency of the averments in a complaint or information is, therefore, whether
    the facts alleged therein, if hypothetically admitted, constitute the elements of the offense.

    To meet the test of sufficiency, therefore, it is necessary to refer to the law defining the offense charged,

    1
    which, in this case, is Article 265 of the Revised Penal Code, which pertinently states:
    Based on the law, the elements of the crime of less serious physical injuries are, namely:
    (1) that the offender inflicted physical injuries upon another; and
    (2) that the physical injuries inflicted either incapacitated the victim for labor for 10 days or more, or the
    injuries required medical assistance for more than 10 days.

    The complaints (see facts) bear out that the elements of less serious physical injuries were specifically
    averred therein. The complaints sufficiently charged the petitioners with less serious physical injuries. It is
    enough to ever the ultimate facts constituting the offense, not the details of why and how the illegal acts
    allegedly amounted to undue injury and damage, for such matters, being evidentiary, were appropriate
    for trial.

    Medical certificates to prove the duration of the victims’ need for medical attendance or of their incapacity
    should take place only at the trial, not before or during the preliminary investigation.

    Petition denied.

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