Case Digest (G.R. No. L-3857) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 2, 1947, in San Enrique, Negros Occidental, Hilarion Sarcepuedes became embroiled in a property dispute with Lucrecia L. Bustamante, a teacher‐nurse at the San Enrique Elementary Public School. Bustamante had ordered the closing of a pathway across her land that Sarcepuedes and his wife customarily used to go to and from the school. In the school building, Sarcepuedes struck Bustamante twice on the face with his raincoat and violently pushed her toward a window. At the time of the assault, Bustamante was about to pierce an earring hole on a pupil’s ear‐lobe in the school clinic—one of her official duties. The Court of First Instance was bypassed when the Court of Appeals convicted Sarcepuedes of direct assault upon a person in authority under Articles 148 and 152, as amended, of the Revised Penal Code. He then appealed by certiorari to the Supreme Court of the Philippines.Issues:
- Was Lucrecia L. Bustamante, as a teacher‐nurse, a person in authority under Articl
Case Digest (G.R. No. L-3857) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Roles
- Hilarion Sarcepuedes – private individual, appellant, accused of direct assault.
- Lucrecia L. Bustamante – teacher-nurse at San Enrique Elementary Public School, respondent, offended party.
- Incident and Circumstances
- Date and Location – September 2, 1947, school building in San Enrique, Negros Occidental.
- Nature of Assault – Sarcepuedes struck Bustamante twice on the face with his raincoat and violently pushed her toward a window.
- Underlying Dispute – Bustamante had closed a pathway across her land used by Sarcepuedes and his wife, prompting Sarcepuedes to seek an explanation.
- Official Duties of Offended Party
- Health Instruction – teaching pupils first aid and sanitary practices in the school clinic.
- Supervisory Role – overseeing sanitary facilities and instructing teachers in medical treatment procedures.
- Procedural History
- Court of Appeals Conviction – convicted under Articles 148 and 152 of the Revised Penal Code for direct assault upon a person in authority.
- Supreme Court Appeal – Sarcepuedes petitioned by certiorari; Supreme Court reviewed the Court of Appeals decision.
Issues:
- Whether Lucrecia Bustamante qualifies as a “person in authority” under Article 152 of the Revised Penal Code.
- Whether the assault occurred “while engaged in the performance of official duties” as required by Article 148.
- Whether the appellant’s extraneous motive bars the application of Articles 148 and 152.
- Whether the penalty imposed by the Court of Appeals conforms to the statutory provisions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)