G.R. No. 83122 - Valenzuela vs. Court of Appeals

On the morning of March 2, 1931, at about 10 o’clock, the accused Leon Acierto entered the office of Hipolito Velasco, the duly appointed postmaster of Bacarra, Ilocos Norte.
The postmaster was in the midst of counting government funds (specifically, two rolls of twenty-peso bills amounting to P4,000) when the accused entered without drawing attention.

Acierto first approached the postmaster silently and, after standing behind him, attempted to take one of the money rolls.
Hipolito Velasco noticed Acierto’s action and intervened by seizing his hand and verbally ordering him to vacate the premises (“Get out of here, Lawyer, because we have plenty of work”).
Despite moving away initially, Acierto returned towards the postmaster’s side, engaging in a repeated refusal to leave even after the postmaster’s reiterated summons.
In the ensuing exchange:

The postmaster repeatedly commanded Acierto to leave his office.
Acierto’s refusal culminated in a physical confrontation where, after the postmaster attempted to escort him out by grabbing his left hand, Acierto struck him in the right eye with his fist.

The blows delivered by Acierto further included additional strikes: first to the right frontal region and then below the left eye.
The postmaster, having sustained an ecchymosis in the orbit of the left eye and in the frontal region, required seven days for full recovery.
A member of the municipal police, along with colleagues present in the office, intervened by separating the two parties and removing them from the hall.

Acierto testified that he had gone to the post office to collect his correspondence and greeted Hipolito Velasco with friendly slaps on the back—a customary gesture between friends.
According to Acierto, when the postmaster did not acknowledge his greetings, he performed a slap on the table.
The postmaster purportedly responded with a verbal threat (“Don’t you come around with your jokes; I may stick a knife into you”), which Acierto claimed provoked him and caused him to attempt to depart.
The defense contended that it was actually the postmaster who obstructed his exit with a threatening posture, leading to a physical altercation initiated in self-defense.

Despite the noted personal familiarity between the parties, the trial court found that Acierto had no right to enter the postmaster’s office while the latter was performing his official duties.
After considering the testimonies, the court gave more credence to the prosecution’s evidence, concluding that the incident escalated into an unprovoked fight resulting in physical injuries to the postmaster.

Whether Acierto’s actions in striking the postmaster could be legally justified as self-defense against an alleged initial assault.
Whether the evidence supports the claim that Acierto was merely attempting to prevent or repel an unlawful attack initiated by Hipolito Velasco.

Whether the postmaster should be legally recognized as a mere public officer or as an agent of authority for purposes of applying the appropriate legal provisions.
The implication of such classification on the charge—specifically, whether the crime committed falls under assault upon a public officer (under Article 251, in conjunction with Article 250) or assault upon an agent of authority (as defined in Article 250, in connection with Article 249, paragraph 2).

Whether the lower court erred in its factual determinations regarding the sequence of events and the applicability of mitigating or aggravating circumstances.
If the evidence was sufficient to impose criminal liability on Acierto for the assault based on the established definitions and thresholds in the Penal Code.