Facts:

• Raymundo Rellin was charged with two crimes:
  1. Direct assault against an agent of authority with homicide (Criminal Case No. 13).
  2. Direct assault against an agent of authority (Criminal Case No. 14).
• The incident occurred on April 4, 1944, around 11 PM in Sta. Cruz, Marinduque.
• Rellin encountered three individuals he found suspicious while heading to a neighborhood association's headquarters.
• The individuals claimed to be part of a patrol inspecting guards.
• Rellin, who was supposed to be on patrol, became agitated and, influenced by alcohol, attacked Graciano Rodas, one of the individuals.
• Rellin's assault caused Rodas to fall, and after a brief struggle, Rodas died from his injuries.
• The lower court, led by Judge Del Rosario, convicted Rellin of simple homicide, sentencing him to an indeterminate prison term and a fine of P2,000 to be paid to Rodas's heirs.
• Rellin was also found guilty of resistance against an agent of authority, receiving a two-month arrest sentence and a P200 fine.
• Rellin appealed the decision.

Issue:

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Ruling:

• The court ruled that Rellin did not commit direct assault against an agent of authority.
• The court affirmed the lower court's decision that Rellin was guilty of simple homicide, not the complex crime of direct assault with homicide.
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Ratio:

• The court's decision focused on the definition of an agent of authority.
• For direct assault to be established, the accused must know the victim is an agent of authority performing their duties.
• Evidence did not show that Rellin recognized Rodas as a municipal police officer during the incident.
• Rodas was not in uniform and did not identify himself as a police officer, leading the court to conclude Rellin believed he was confronting suspicious individuals...continue reading