Title
People vs. Lapitan
Case
G.R. No. 38226
Decision Date
Nov 17, 1933
Two appellants were convicted and sentenced to two months and one day of arresto mayor plus a P150 fine for assaulting a police officer in the performance of his duties.
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Case Digest (G.R. No. 38226)

Facts:

  • The case involves The People of the Philippine Islands vs. Luis Lapitan and Dalmacio Lapitan.
  • Defendants were charged with assaulting an agent of a person in authority on January 29, 1932, in Rizal, Nueva Ecija.
  • The dispute centered around 52 cavans of palay (rice) levied due to civil case No. 2046 initiated by Laureana Aves against Pedro Ablao.
  • An execution order was issued on December 10, 1931, by the justice of the peace of Cabanatuan.
  • Luis Lapitan filed a third-party claim for the palay on January 14, 1932.
  • The provincial sheriff directed the chief of police to deliver the palay to Lapitan.
  • On January 22, 1932, the sheriff ordered the chief of police to reclaim the palay after the judgment creditor provided an indemnity bond.
  • On January 29, 1932, while municipal policeman Juan Sambrano was monitoring the palay, the defendants arrived with carts and insisted on taking it.
  • An altercation occurred where Dalmacio struck Sambrano, and Luis threatened him with a gun.
  • The trial court, led by Judge E. V. Filamor, found Luis and Dalmacio guilty under Article 151 of the Revised Penal Code, sentencing them to two months and one day of arresto mayor and a fine of P150, while Gaudencio was acquitted.
  • The appellants appealed the trial court's decision, claiming errors in the judgment.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the lower court's decision.
  • The court upheld the conviction of Luis and Dalmacio Lapitan for assaulting Juan Sambrano....(Unlock)

Ratio:

  • The Supreme Court found the trial court's findings were supported by substantial evidence, particularly the testimony of Juan Sambrano, who was performing his duties as a municipal policeman.
  • The court emphasized that the actions of the appellants constituted a clear violation of Article 151, which penalizes ...continue reading

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