G.R. No. L-4674
THE UNITED STATES, plaintiff-appellee, vs. VICTORIANO PANALIGAN, defendant-appellant.
August 23, 1909

FACTS:
Victoriano Panaligan, the defendant, was selling sinamay in a public market when a dispute arose between him and a woman who refused to pay for 3 yards of sinamay he had cut for her. Policeman Nicomedes R. Nera, who had previously attempted to buy sinamay from Panaligan at a lower price, interfered in the argument. Panaligan requested the policeman not to interfere in his private matters. The policeman claimed Panaligan drew a knife threateningly, which Nera then knocked out of his hand with a club. Panaligan, however, asserted that Nera took the knife from his pocket where he had placed it after cutting the fabric. The lower court found Panaligan guilty of “attempt against an agent of the authorities” under Article 250 of the Penal Code and sentenced him to imprisonment and a fine. Panaligan appealed, challenging the sufficiency of the facts to support the conviction.

ISSUE:
Whether the defendant’s actions constituted an “attempt against an agent of the authorities” under the circumstances, specifically if the policeman was acting within his official duty when he interfered in the private dispute.

RULING:
The Supreme Court reversed the lower court’s judgment, dismissed the case, and discharged the defendant. The Court found that there was no reason for the policeman’s interference in the altercation between Panaligan and the woman. The record contained no evidence to justify a finding that Panaligan resisted the policeman, showed him disrespect, or interfered with him in the performance of his duty. The Court determined that the policeman’s conduct was “nothing more than that of meddlesome interference in a matter with which he had nothing to do,” and that Panaligan was justified in requesting the policeman not to interfere in his private affairs. Thus, there was no factual basis to justify the penalty imposed by the lower court.