G.R. No. 4642 : THE UNITED STATES, plaintiff-appellee, vs. SIDNEY LEE BAYLEES, defendant-appellant. (August 28, 1908)

FACTS:
On December 22, 1907, Corporal Nemesio Ilaya, accompanied by two other uniformed policemen, went to a saloon to arrest Sidney Lee Baylees. They possessed a warrant for Baylees’ arrest, issued due to an “attempt against the agents of the authorities” committed on December 15, 1907. Corporal Ilaya served the warrant and instructed Baylees to accompany them. Baylees, despite understanding Tagalog, refused, demanding a Spanish interpreter. He then invited Corporal Ilaya outside. As Ilaya stepped out, Baylees fired his revolver, with the bullet passing through the door frame where Ilaya was standing, after which Baylees fled. The trial court found these facts, supported by witness testimonies, to be satisfactorily established. Baylees knew the individuals were policemen and understood their intent to arrest him for the earlier incident.

ISSUE:
Whether the crime committed by Sidney Lee Baylees was properly qualified as a criminal attempt against the agents of the authorities.

RULING:
Yes. The Supreme Court affirmed the lower court’s judgment, ruling that the crime was properly qualified as a criminal attempt against the agents of the authorities, punishable by Article 249, No. 2, in connection with Article 250, No. 1, of the Penal Code. The Court found no mitigating or aggravating circumstances. Consequently, the judgment sentencing Sidney Lee Baylees to four years, two months, and one day of prision correccional, a fine of 1,000 pesetas (with subsidiary imprisonment in case of insolvency), accessory penalties, and costs, was affirmed in its entirety.