US vs.

Villanueva
GR No. 10606; September 11, 1915
Arellano, C.J

TOPIC: Art. 4. Criminal liability. — Criminal liability shall be incurred:

1. By any person committing a felony (delito) although the wrongful act done be different from
that which he intended.

2. By any person performing an act which would be an offense against persons or property,
were it not for the inherent impossibility of its accomplishment or an account of the employment
of inadequate or ineffectual means.

FACTS:

Villanueva is charged "while quarreling with his opponent, Isidro Benter, with having suddenly
snatched the bolo which the latter was carrying at his belt and with it inflicting upon him a wound
in the palm of the right hand that incapacitated the aggrieved party from performing work for
more than thirty days and which rendered Benter entirely useless.

However, it turned out that Villanueva was not Benter's opponent nor was there any quarrel
between the two. Neither did Villanueva inflict wound upon Benter. The latter injured himself by
an accident arising out of his own act.

Benter himself testified that he had agreed to take Villanueva to the town of Pola in his boat;
that on arriving at the landing boat was not there; that, thereupon he told Villanueva that to
avoid being late the latter ought to start right away; that while both of them were standing with
their arms folded it occurred to Villanueva to take hold of the bolo which complainant carried at
his belt; that the complainant tried to retain it and that in doing so he caught it by the blade and
cut himself in the palm of the right hand; that without a word being said, either before or
afterwards, Villanueva being in the best of temper, on finding himself injured the complainant left
the spot while Villanueva remained there.

ISSUE:

Whether or not Benter is guilty of the crime of inflicting serious physical injuries.

HELD:

No.

A person is guilty of the crime of inflicting physical injuries (iesiones) who, either with malice or
with reckless imprudence, wounds, strikes or assaults another and thereby inflicts any injury. If
the defendant did not wound, strike, or assault the person who calls himself the aggrieved party,
nor cause him any injury whatever, it appearing that the aggrieved person wounded himself, he
cannot be held liable for the crime of lesiones—not even by reckless imprudence.
In the case at bar, the defendant did not wound, beat, or assault Benter; consequently, he
cannot be guilty of the crime of inflicting serious physical injuries, not even by reckless
imprudence.