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PEOPLE vs. BELTRAN- Marianne S.

Nos. L- 37168-69
September 13, 1985
Doctrine: Direct Assault- Shooting at the mayor and a policeman in considered as
direct assault.
Facts: Accused appellants in this case were Delfino Beltran (Minong), Rogelio
Bugarin (Boy), Cresencio Siazon (Ising), Manuel Puzon (Noling), Domingo
Hernandez (Doming), and Ceferino Beltran (Ebing). They convicted by the trial
court of murder for the death of Vicente Quirolgico, the mayors son and double
attempted murder with direct assault for injuries sustained by Mayor
Bienvenido Quirolgico and Patrolman Rolando Tolentino. The trial court based its
conclusion on the following facts:
Based on a report by Ernesto Alvarado that when he passed by the Puzon
Compound on January 11, 1972 between 9pm-10pm he was verbally assaulted by
Delfino Beltran, Mayor Quirolgico went to the Puzon compound on that same night
to talk to Beltran and his companions and to ask them to surrender. When the
Mayors party approached the compound, they saw appellants Delfino Beltran,
Bugarin, and Hernandez followed by a simultaneous discharge of firearm. Vicente
was hit. Mayor Quirolgico and Patrolman Tolentino also suffered injuries. When the
firing had stopped, they decided to bring Vicente to the hospital but as the jeep left
the compound, three other men in the persons of Siazon, Ceferino Beltran, and
Puzon fired at the fleeing vehicle. Likewise, Hernandez, Delfino, and Bugarin tried to
give chase. An hour after admission, Vicente died.
Defense: Delfino Beltran claimed self-defense, explaining that he was assaulted by
Mayors group while he was patrolling the Rural Bank whereas the rest of the
accused claim that they do not have anything to do with the incident.
Accused-appellant Siazon died during the course of the case thereby dismissing his
criminal liability.
In this appeal, one of the assigned errors of the accused-appellants to the trial court
was that it erred in finding them guilty of attempted murder with direct assault.
Issue: Whether or not the Mayor and Pat. Tolentino are persons in authority and
were both performing the official duties in the course of the incident.
Held: Yes. The Court ruled that the decision of the trial court to convict them of the
crime of attempted murder with direct assault is correct because the Mayor and Pat.
Tolentino are persons in authority and both were performing their official duties to
maintain peace and order in the community.
Dispositive: The Court affirmed the decision of the trial court with modification. Of
significance is the modification that for the lack of necessary votes, the penalty of

death imposed upon the accused by the trial court for the death of Vicente, was
reduced to Reclusion perpetua.