G.R. No. 4367
THE UNITED STATES, plaintiff-appellee, vs. SALVADOR VALLEJO, ET AL., defendants-appellants.
September 3, 1908

FACTS:
On May 17, 1907, municipal policemen Tranquilino Saravillo and Dalmacio Sabio were dispatched to the house of Salvador Vallejo in Polangui, Albay, following a complaint of public disturbance. From outside, the policemen heard Vallejo shouting obscenities loudly and running inside his house, creating a public annoyance and breach of peace.

Upon approaching, the uniformed policemen went upstairs and knocked. Vallejo confronted them at the door, demanding a warrant. When informed they had none, he immediately punched both policemen. As the policemen attempted to arrest Vallejo for resisting, Blas Ausina intervened by embracing Vallejo, pulling him inside, and closing the door, thus preventing the arrest. Vallejo was a sanitary officer (a public official) and was intoxicated at the time, though not an habitual drunkard.

The Court of First Instance found both Vallejo and Ausina guilty of an attempt against an agent of authority.

ISSUE:
1. Can a person claim the inviolability of their dwelling to justify a public disturbance or aggression against public officers, even if committed within their own house?
2. Did municipal policemen, in the absence of an express statutory grant, have the power to arrest without a warrant for a breach of the peace committed in their presence?
3. Does a prior conviction for disorderly conduct under a municipal ordinance constitute double jeopardy for the subsequent charge of resistance to an agent of authority under the Penal Code, arising from the same incident?

RULING:
1. No. While a man’s house is his castle, it cannot be used as a citadel for aggression against neighbors, nor can he within its walls create such disorder as to affect their peace. Vallejo’s behavior, though within his house, amounted to more than private misconduct and constituted a public annoyance and a breach of the neighborhood’s peace.
2. Yes. In the absence of an expressed legislative definition of their faculties, duly appointed municipal police officers in the Philippines are assumed to possess those powers necessary for the convenient exercise of the duties for which their offices were created. This includes the common law powers of a “peace officer” under English and American law, such as the power to arrest without a warrant for offenses like a breach of the peace committed in their presence.
3. No. Citing United States vs. Gavieres (10 Phil. Rep., 694), the Court affirmed that double prosecution under a municipal ordinance and a general law (Penal Code) is permissible, even if the acts of resistance were specified as part of the disorder in the initial prosecution. The defense of double jeopardy was therefore overruled.

Disposition: The Court found Salvador Vallejo guilty of resistance to an agent of authority (Article 249, paragraph 2 of the Penal Code), aggravated by his status as a public official (Article 250, subdivision 2), but mitigated by non-habitual drunkenness. He was sentenced to prision mayor for two years, four months, and one day, with a P100 fine. Blas Ausina was also found guilty of resistance to an agent of authority (Article 249, paragraph 2 of the Penal Code) and sentenced to prision correccional for one year, eight months, and twenty-one days, with a P100 fine. The lower court’s sentence was revoked and modified accordingly.