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The Court can, thus, only convict accused-appellant of slight physical injuries. Under par. 1, Art.

266 of
the RPC, the penalty for slight physical injuries is arresto menor “when the offender has inflicted physical
injuries which shall incapacitate the offended party for labor from one to nine days, or shall require
medical attendance during the same period.” There being no modifying circumstances to be appreciated,
and in accordance with par. 1 of Art. 64,[35] accused-appellant should be meted a penalty of
imprisonment of arresto menor in its medium period, which has a duration of eleven (11) to twenty (20)
days under Art. 76 of the RPC. ( PEOPLE OF THE PHILIPPINES vs CECILIA LAGMAN y PIRING, G.R. No.
197807)

Three kinds of slight physical injuries:

1. Physical injuries which incapacitated the offended party for labor from (1) to nine (9) days, or
required medical attendance the same period

2. Physical injuries which did not prevent the offended party from engaging in his habitual work or
which did not require medical attendance

3. Ill-treatment of another by deed without causing any injury.

Ex

Contusion on the face or black eye produced by fistic blow

Slapping but without causing dishonor

When the injury created a deformity upon the offended party, you disregard the healing duration or the
period of medical treatment involved. At once, it is considered serious physical injuries.

So even though the deformity may not have incapacitated the offended party from work, or even though
the medical treatment did not go beyond nine days, that deformity will bring about the crime of serious
physical injuries.

Deformity requires the concurrence of the following conditions:

(1) The injury must produce ugliness;

(2) It must be visible;

(3) The ugliness will not disappear through natural healing process.

Illustration:

Loss of molar tooth – This is not deformity as it is not visible.

Loss of permanent front tooth – This is deformity as it is visible and permanent.


Loss of milk front tooth – This is not deformity as it is visible but will be naturally replaced.

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