People v. Quebral
REITERATIONFacts
The Antecedents: On or about July 12, 1940, the defendants-appellees allegedly feloniously assaulted and attacked Dr. Jose R. Sison, president of the 6th sanitary division, while he was engaged in the performance of his official duties, causing him several physical injuries. Procedural History: The Court of First Instance of Pangasinan sustained a motion to quash the information charging the defendants-appellees with assault upon a person in authority. The Petition: The Solicitor-General appealed, arguing that the lower court erred in holding that the president of a sanitary division is not a person in authority or an agent of a person in authority under Article 148 of the Revised Penal Code.
Issue(s)
Whether the president of a sanitary division is a person in authority or an agent of a person in authority within the purview of Article 148 of the Revised Penal Code.
Ruling
The appealed order is reversed and set aside, and the case is remanded to the court of origin for further proceedings.
Ratio Decidendi
On the issue of whether the president of a sanitary division is a person in authority or an agent of a person in authority: The Court held that the president of a sanitary division is indeed a person in authority or, at least, an agent of such a person within the purview of Article 148 of the Revised Penal Code. The law expressly vests in the president of a sanitary division the power to enforce all sanitary laws and regulations applicable in his division and to cause all violations thereof to be duly prosecuted. Although subject to the direction of the district health officer, the discharge of this legal duty is directly imposed by law upon him. Even if the enforcement of sanitary laws were considered within the jurisdiction of the district health officer, the president of a sanitary division, in actually performing such duty in representation of the former, logically becomes his agent. This conclusion finds precedent in the case of People vs. Marquez, G.R. No. 41527, which held that a sanitary inspector is an agent of a person in authority. The separate opinion further elaborated that the president of a sanitary division exercises his powers and duties under the supervision of the District Health Officer, but this supervision does not divest the Division President of his inherent authority and jurisdiction granted by law to enforce sanitary laws and regulations within his division. The act of Dr. Sison in visiting the laboratory, even if it was to present a letter from the Board of Pharmaceutical Examiners, was an exercise of his official duties, irrespective of the letter itself.
Main Doctrine
The president of a sanitary division is considered a person in authority or, at least, an agent of a person in authority within the purview of Article 148 of the Revised Penal Code when performing official duties.