Case Summary (G.R. No. L-4366)
Background of the Case
Juan Garcia was arrested and subsequently tried in the Court of First Instance of Bulacan. He was found guilty, sentenced to four months and one day of imprisonment (arresto mayor), fined 325 pesetas, and potentially subjected to subsidiary imprisonment for insolvency. Garcia appealed the decision, leading to a review by the court.
Evidence Considered by the Court
Upon review, the evidence presented indicated unequivocally that Garcia entered the house without the express permission of Manuel Villariba. However, critical to the case was the fact that Garcia entered the dwelling at the invitation of Marciana Villariba, who resided in the house. This detail became pivotal in determining the legal standing of Garcia’s actions.
Legal Findings and Precedents
The court referenced prior jurisprudence, particularly U.S. vs. Agas, which establishes that if a defendant enters a dwelling upon the request of an occupant, they cannot be held liable for allanamiento de morada. The court reiterated that mere presumption of an entry being against the owner's will is insufficient; concrete evidence of a lack of consent from the owner must be established.
Conclusion of the Court
In light of the evidence and established legal principles, the court concluded that Marciana Villariba’s invitation to Garcia nullifie
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Case Reference
- G.R. No. 4366
- Date of Decision: February 28, 1908
- Court: Supreme Court of the Philippines
Background
- The defendant, Juan Garcia, was charged with allanamiento de morada (forcible entry of a dwelling).
- The charge specified that on April 3, 1907, in Polo, Bulacan, the defendant entered the house of Manuel Villariba without permission.
Proceedings in the Lower Court
- Juan Garcia was arrested based on the complaint and tried in the Court of First Instance of Bulacan.
- The outcome of the trial:
- Found guilty of the crime.
- Sentenced to four months and one day of arresto mayor.
- Ordered to pay a fine of 325 pesetas.
- Subject to subsidiary imprisonment in case of insolvency.
- Required to pay court costs.
Appeal to the Supreme Court
- The defendant appealed the lower court's decision to the Supreme Court.
Evidence and Findings
- The Supreme Court examined the evidence and established that:
- Juan Garcia did enter the house of Manuel Villariba on the night in question.
- He entered the house at the express invitation of Marciana Vi