FACTS:

The case involves the petitioner being charged and convicted for serious physical injuries under Article 263(3) of the Revised Penal Code. The incident occurred when the petitioner punched the respondent, causing the latter to suffer a fractured front tooth and permanent deformity. The prosecution presented witnesses who testified that the petitioner initiated the altercation and punched the respondent without provocation. On the other hand, the petitioner claimed that the respondent threw the first punch and that he only retaliated in self-defense. The municipal trial court, regional trial court, and Court of Appeals all found the petitioner guilty, with the latter concluding that a fractured tooth resulting in permanent deformity qualifies as a serious physical injury. The petitioner filed a petition for review, arguing that the respondent was intoxicated and that his tooth was only fractured, not extracted. The petitioner also contended that a fractured tooth does not constitute a deformity or loss of a body part as required by the law. Additionally, the lack of jurisprudence on the matter and the reliance on a 1934 case, People v. Balubar, were pointed out by the petitioner.

ISSUES:

1. Whether the loss of a tooth qualifies as a permanent deformity within the scope of the crime of serious physical injuries.

2. Whether the ruling in People v. Balubar, which held that the loss of teeth constitutes a disfigurement, should still be followed.

3. Whether the loss of four front teeth constitutes a serious physical injury under Article 263(3) of the Revised Penal Code.

4. Whether the loss of a tooth can be considered a serious physical injury under Article 263 of the Revised Penal Code.

5. Whether the penalty of slight physical injuries under Article 266 should be imposed when there is no visible deformity resulting from the loss of a tooth.

6. Whether Elpedio Ruego is guilty of physical injuries under Article 266(1) of the Revised Penal Code.

7. Whether Elpedio Ruego should be held liable for the dental costs of the respondent.

RULING:

1. The loss of a tooth qualifies as a permanent deformity within the scope of the crime of serious physical injuries.

2. The ruling in People v. Balubar should not be followed.

3. The Supreme Court held that the loss of four front teeth constitutes a serious physical injury under Article 263(3) of the Revised Penal Code. The Court reasoned that the loss of teeth causes a permanent and visible disfigurement, which cannot be remedied by nature. The fact that artificial teeth can be substituted for the lost teeth does not repair the injury, although it may lessen the disfigurement. Therefore, the defendant is guilty of a violation of Article 263(3) of the Revised Penal Code.

4. The loss of a tooth cannot be automatically classified as a serious physical injury under Article 263. A factual determination must be made during trial as to whether the loss of the tooth resulted in a visible deformity. If no deformity is apparent, a lesser penalty should be imposed.

5. In this case, since the defendant did not show any visible deformity resulting from the loss of a tooth, the offense should be categorized as slight physical injuries under Article 266.

6. Elpedio Ruego is found guilty of slight physical injuries under Article 266(1) of the Revised Penal Code.

7. Elpedio Ruego is sentenced to imprisonment of arresto menor and is ordered to pay the dental costs of the respondent, as determined by the Municipal Trial Court in Cities of Iloilo City.

PRINCIPLES:

• The text of Article 263(3) of the Revised Penal Code does not include the word "tooth" or "teeth."

• The loss of teeth is not per se a disfigurement since they can be replaced by artificial teeth.

• The loss of teeth impairs one's appearance and constitutes a disfigurement if it is visible and impairs the appearance of the offended party.

• The injury contemplated by Article 263(3) of the Revised Penal Code is an injury that cannot be repaired by the action of nature.

• One who unlawfully wounds another is responsible for the consequences of his act.

• If the offended party is impaired in appearance in such a way that the disfigurement cannot be removed by nature, the person causing the injuries is responsible for the disfigurement.

• Artificial teeth may lessen the disfigurement caused by the loss of natural teeth but do not repair the injury.

• The loss of eyes, ears, limbs, or any other part of the body that visibly alters one's physical appearance and body functions constitutes a deformity under Article 263(3) of the Revised Penal Code.

• Deformity under Article 263(3) refers to visible ugliness, permanent and visible physical abnormality.

• The decisions of the Supreme Court of Spain are persuasive but not binding on the Supreme Court of the Philippines, which is at liberty to take a progressive stand in interpreting the Revised Penal Code.

• Trial courts should consider all the factual circumstances surrounding the injury and its resulting consequences when imposing penalties.

• The loss of a tooth must be shown to have resulted in a visible deformity to be classified as a serious physical injury.

• In the absence of visible deformity, a lesser penalty should be imposed.

• Well-meaning friends and relatives should endeavor to de-escalate a situation and avoid judicial interference.

• Parties should attempt to settle their issues before resorting to court.