Title
People vs. Balbar
Case
G.R. No. L-20216
Decision Date
Nov 29, 1967
A teacher assaulted in a classroom during class; charges of direct assault upheld, acts of lasciviousness dismissed due to lack of lewd intent.

Case Summary (G.R. No. L-20216)

Key Dates

  • Incident: August 29, 1960
  • Lower Court Quash Order: August 16, 1962
  • Supreme Court Decision: November 29, 1967

Applicable Law

  • 1935 Philippine Constitution
  • Revised Penal Code
    • Article 148 (Direct Assault Upon a Person in Authority)
    • Article 336 (Acts of Lasciviousness)
  • Commonwealth Act No. 578 (now codified as Article 152, RPC)

Allegations and Informations

  • Criminal Case No. 823 (Direct Assault)
    • Accused entered Gonzales’s classroom, placed arms around her, kissed her, displayed a local dagger (“daga”), pursued her, caused physical injury.
    • Charged as assault upon a person in authority, with aggravation for commission during school hours and inside a school building.
  • Criminal Case No. 841 (Acts of Lasciviousness)
    • Same factual setting, alleged deliberate intent to satisfy lust by embracing and kissing the teacher against her will, resulting in minor injuries.
    • Charged with lascivious acts, aggravated by venue and time.

Lower Court Proceedings

  • Respondent moved to quash both informations, alleging:
    1. Case 823 failed to state a sufficient cause of action and improperly joined two offenses.
    2. Case 841 subjected him to double jeopardy and charged two offenses.
  • The Court of First Instance quashed both informations:
    • Case 823 deemed at most “unjust vexation” (i.e., physical injuries within Justice of the Peace jurisdiction) for lack of allegation that the accused knew the victim was in authority.
    • Case 841 held absorbed in Case 823 and therefore dismissed.
  • Government appealed.

Issues on Appeal

  1. Whether the information in Case 823 properly sustains the charge of Direct Assault Upon a Person in Authority.
  2. Whether the acts alleged in Case 841 constitute Acts of Lasciviousness under Article 336, RPC.

Supreme Court Analysis on Direct Assault

  • Article 148, RPC, punishes assault or intimidation of any person in authority while performing official duties.
  • Commonwealth Act No. 578 explicitly classifies public school teachers as persons in authority under Article 148.
  • Knowledge that the victim is a person in authority is a matter of law, not fact; presence in the classroom during official duties suffices to charge that the accused knew her status.
  • The absence of an express averment of knowledge in the information does not invalidate the charge.
  • Conclusion: The lower court erred in quashing Case 823; the information states a valid cause of action for Direct Assault Upon a Person in Authority.

Supreme Court Analysis on Acts of Lasciviousness

  • Article 336, RPC, punishes lewd or lascivious conduct, to be determined by surrounding circumstances.
  • Embrace and kiss in a public schoolroom, before students and colleagues, do not manifest a
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