9/22/25, 7:39 PM People vs.
Mendoza
Title
People vs. Mendoza
Case Decision Date
G.R. No. 39275 Dec 20, 1933
A teacher, not a person in authority, was slapped by a student; the Supreme Court ruled it
a light felony, dismissing the case for lack of jurisdiction.
Jur.ph - Case Digest (G.R. No. 39275)
Expanded Legal Reasoning Model
Facts:
Parties and Proceedings
The People of the Philippine Islands, through the Provincial Fiscal of Pampanga,
filed Information No. 4851 against defendant Ricardo Mendoza for the crime of
“assault upon a person in authority.”
The Information alleged that on or about September 30, 1932, in San Fernando,
Pampanga, Mendoza, a pupil, willfully and criminally slapped his teacher,
Iluminada Tinio, while she was performing her duties inside the high school
building.
Trial Court Disposition and Appeal
Upon Mendoza’s motion, the trial court dismissed the Information on the ground
that the alleged acts constituted only a misdemeanor or light felony, not assault on a
person in authority.
The Provincial Fiscal appealed to the Supreme Court, invoking earlier decisions
(People vs. Villacenda, Lagrimas, Tacud) that treated similar acts as assault upon an
agent of authority.
Issues:
Whether the facts alleged in the Information constitute:
The crime of assault upon a person in authority or an agent thereof under the
Revised Penal Code; or
Any grave or light felony.
Ruling:
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9/22/25, 7:39 PM People vs. Mendoza
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Ratio:
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Doctrine:
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