People vs.

Buling
107 Phil 712 Section 21 Supervening facts
FACTS:
Accused was charged with less serious physical injury to another person in which the former pleaded
guilty. After serving his sentence, the wounds inflicted by the accused allegedly did not heal. So, another
complaint was filed against him, this time, he was charged with serious physical I injury.
This is now the case at bar sought to be reversed and set aside by the accused.
ISSUE: Whether the prosecution and conviction of Balaba for less serious physical injuries is a bar to the second
prosecution for serious physical injuries.
RULING:

YES. Unlike in the case of Melo v. People, there was no supervening facts in this case which would allow for
the subsequent charge against the accused even after serving his sentence. The physical injury then
committed was the same physical injury being brought up by the prosecution. Thus, there was no change
in the nature of the injury suUnnatural death