Case Digest (G.R. No. 17332) Core Legal Reasoning Model
Facts:
In October 1919, Cecilio Toledo was president of the "Philippine Marine Union" and had the privilege of residing in a room located at house No. 507, Jaboneros Street, rented by the association. Toledo was dismissed from his post mid-October and replaced by Olimpio de Peralta. On October 16, 1919, Peralta entered the room to retrieve a desk glass he believed belonged to the union. This action led to charges of trespass to dwelling against Peralta, alleging that he entered Toledo’s room without the occupant’s consent. During trial, witnesses for the prosecution testified that Peralta pushed open the closed door without permission and entered forcibly, while defense witnesses claimed he merely called at the door and entered accompanied by Lucia Matias, whom he met outside, to look for the desk glass. The lower court convicted Peralta, sentencing him to two months and one day of arresto mayor and a fine of 400 pesetas. Peralta appealed the decision.
Issues:
- Did Olimpio
Case Digest (G.R. No. 17332) Expanded Legal Reasoning Model
Facts:
- Background
- Cecilio Toledo was president of the "Philippine Marine Union" around October 1919.
- As president, Toledo occupied a room in house No. 507 on Jaboneros Street rented to the association.
- In mid-October 1919, Toledo was discharged and succeeded by Olimpio de Peralta.
- Incident
- On the morning of October 16, 1919, Peralta entered Toledo’s room to look for a desk glass believed to belong to the union.
- Two prosecution witnesses, Lucia Matias and Daniel Alvarado, testified that Peralta entered without permission and possibly by force:
- Matias said the door was closed; Peralta pushed it open and entered. She asked why he entered without permission.
- Alvarado stated he saw Peralta strike or kick the door to gain entry.
- Defense witnesses, Bernardo Bildad and Bonifacio Viloria, testified that Peralta entered accompanied by Matias to look for the desk glass between 10:30 and 11:00 a.m. and implied familiarity with the room.
- Trial outcome and appeal
- Peralta was convicted of trespass to dwelling, sentenced to two months and one day of arresto mayor, a fine of 400 pesetas, plus costs.
- Peralta appealed the judgment.
Issues:
- Whether Peralta’s entry into Toledo’s room constituted trespass to dwelling under Article 491 of the Penal Code.
- Whether Peralta entered against the express or presumed will/prohibition of the occupant.
- Whether the mere lack of permission to enter equals the crime of trespass.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)