G.R. No. 1687 : January 31, 1905
THE UNITED STATES, complainant-appellee, vs. MARIA SOLIS, ET AL., defendants-appellants.

FACTS:
On June 12, 1903, Gregoria Magabilin was at the house of Maria Solis. Maria Solis confronted Magabilin about an alleged statement concerning land granted by her brother, Victoriano Solis. When Magabilin denied making the statement, Maria Castellon, a servant, struck Magabilin in the mouth. Victoriano Solis intervened. Subsequently, Fernando Solis struck Magabilin in the temples. Maria Solis then dragged Magabilin by the hair along the ground and bit her left ear, resulting in the loss of part of the ear lobule and a pair of earrings. The injury caused permanent disfigurement. The defendantsMaria Solis, Fernando Solis, and Maria Castellonwere charged with lesiones graves (grave physical injuries).

ISSUE:
Whether all three defendants are liable for the crime of lesiones graves.

RULING:
The Supreme Court affirmed the conviction of Maria Solis for lesiones graves under Article 416 of the Penal Code but acquitted Fernando Solis and Maria Castellon of that crime. The Court found no conspiracy among the defendants. The grave injury (the bitten ear causing permanent disfigurement) was solely and directly inflicted by Maria Solis. Fernando Solis and Maria Castellon, who only struck the victim with their fists without causing serious injury, were held liable only for the misdemeanor of ill-treatment. For Maria Solis, the Court considered two extenuating circumstances with no aggravating circumstances to offset them, thus imposing the penalty next lower in degree. Fernando Solis and Maria Castellon were each fined ten pesos for ill-treatment. The judgment of the Court of First Instance was modified accordingly.