Case Digest (G.R. No. 202181) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On February 10, 2016 at about 4:30 PM in Purok Santan B, San Jose District, Pagadian City, petitioner Rochard Balsamo y Dominguez allegedly had an altercation with his neighbor, Dexter Cris Adalim, who called his brother, Police Officer 3 Policarpio Adalim III (PO3 Adalim), for help. PO3 Adalim and Police Officer 1 Gerome Tare, both in civilian clothes, arrived and identified themselves as police officers. As they tried to restore order, petitioner fled toward his house. PO3 Adalim pursued him, grabbed his right arm, and was struck on the chest by petitioner’s fist. Petitioner then slammed his gate, injuring the officer’s fingers. PO3 Adalim suffered slight abrasions and finger swelling but continued to chase petitioner until bystanders assisted in his surrender. Petitioner was charged with direct assault under Article 148 of the Revised Penal Code before the Municipal Trial Court in Cities (MTCC). The MTCC found him guilty, sentencing him to four months and one day of arresto m Case Digest (G.R. No. 202181) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident
- On February 10, 2016 at around 4:30 p.m., Dexter Cris Adalim informed his brother, Police Officer 3 (PO3) Policarpio Adalim III, that their neighbor, Rochard Balsamo, had punched and threatened to shoot him.
- PO3 Adalim and Police Officer 1 Gerome Tare, both in civilian clothes, responded. Upon arrival, they saw Rochard charging at Dexter. PO3 Adalim shouted “stop” and introduced himself as a police officer.
- Rochard fled; PO3 Adalim chased and grabbed his right arm. Rochard punched PO3 Adalim in the chest. Rochard then slammed his gate, catching and injuring PO3 Adalim’s fingers, causing slight abrasions and swelling.
- Bernardo Bayoyo helped convince Rochard to surrender, and he was arrested without further incident.
- Procedural History
- Rochard was charged with direct assault under Article 148, Revised Penal Code (RPC). He denied knowing the men were police officers and claimed self-defense.
- The Municipal Trial Court in Cities (MTCC) convicted him of direct assault (4 months + 1 day to 1 year + 1 month prision correccional; fine PHP 500).
- The Regional Trial Court (RTC) affirmed the conviction, ruling that Rochard knew the assailants were officers performing official duties.
- The Court of Appeals (CA) likewise affirmed all elements of direct assault. Rochard filed a Petition for Review on Certiorari before the Supreme Court.
Issues:
- Whether Rochard’s use of force against PO3 Adalim constitutes direct assault under Article 148, RPC, or merely resistance/disobedience under Article 151, RPC.
- Whether the CA erred in affirming the conviction for direct assault given the nature and severity of the force employed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)