Title
People vs. Mendoza
Case
G.R. No. 39275
Decision Date
Dec 20, 1933
A teacher, not a person in authority, was slapped by a student; the Supreme Court ruled it a light felony, dismissing the case for lack of jurisdiction.

Case Digest (G.R. No. 39275)
Expanded Legal Reasoning Model

Facts:

  • Parties and Proceedings
    • The People of the Philippine Islands, through the Provincial Fiscal of Pampanga, filed Information No. 4851 against defendant Ricardo Mendoza for the crime of “assault upon a person in authority.”
    • The Information alleged that on or about September 30, 1932, in San Fernando, Pampanga, Mendoza, a pupil, willfully and criminally slapped his teacher, Iluminada Tinio, while she was performing her duties inside the high school building.
  • Trial Court Disposition and Appeal
    • Upon Mendoza’s motion, the trial court dismissed the Information on the ground that the alleged acts constituted only a misdemeanor or light felony, not assault on a person in authority.
    • The Provincial Fiscal appealed to the Supreme Court, invoking earlier decisions (People vs. Villacenda, Lagrimas, Tacud) that treated similar acts as assault upon an agent of authority.

Issues:

  • Whether the facts alleged in the Information constitute:
    • The crime of assault upon a person in authority or an agent thereof under the Revised Penal Code; or
    • Any grave or light felony.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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