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EOPLE V.

CALERA AND CANTELA

FACTS: Juan CALINDONG was the municipal mayor of Catarman, Samar. He issued a call to all the
municipal officials and employees of the municipality for a conference/meeting. The purpose of the
meeting was to “readjust” the assignment of official duties of the employees to assist or harmonize with
the newly established Commonwealth government at that time. So the meeting was held at the
municipal hall around 4pm on November 17, 1945. Among those who attended the meeting were
municipal councilors, the mayor, vice mayor, treasurer the chief of police of the town and his assistants.
The meeting was called to order by Mayor Calindong who explained the purpose of the conference and
the importance of maintaining the law and public order. He then called on municipal councilor
CAMPOSANO to speak before the audience. Councilor Camposano asked the mayor whether he would
take responsibility for what he was about to say to the audience. Then, the chief of police (and accused
appellant) CALERA stood up, quite agitated, telling Camposano that the mayor cannot be responsible for
whatever he was going to say. Basically, Councilor Camposano was supposed to speak about a certain
municipal ordinance and Calera was disrupting him from speaking because he won’t sit down even if
ordered to by the mayor. Calera was agitated because he feels that Camposano was going to criticize
and speak against the police force. As a result, there were exchange of words, shouting between the
mayor, the councilor and the chief of police. Due to the confusion, there was disorder in the municipal
hall and the audience rushed out of the hall and the meeting was DISSOLVED. The justice of peace
present in the meeting tried to break up the fight between the 3 but failed. SO the meeting was never
finished. Now, the Calera faces charges of violation of Art 131 of the RPC (prohibition interruption, and
dissolution of peaceful meetings).

ISSUE: W/N Calera is guilty of dissolving or interrupting a meeting under Art 113. NO!

HELD/RATIO: The provision in Art 131 of the RPC is intended to penalize the act of a public official who
shall prohibit, stop or otherwise interrupt the holding and/or dissolve a peaceful meeting. But in order
to be liable under this provision, it is necessary that the accused be a STRANGER, not a participant, of
the meeting that has been interrupted and eventually dissolved. In this case, the said conference was
called by the mayor and one of the officials invited to attend the same was the appellant Calera (chief of
police). So he is not a stranger to the meeting. He was not only present in the meeting but he also took
direct part in the said proceeding. Art 131 is found under the title Crimes Against the Fundamental
Laws of the State. It’s specific purpose is to penalize the prohibition, interruption and dissolution of
peaceful meetings by a stranger. This is NOT that kind of situation.

Side issues: SC held that Calera cannot he held criminally liable under Art 144 (disturbance of
proceedings) either. This is because the conference in question is not a meeting of the municipal council.
It was in fact convened by the mayor. (the proceedings contemplated in this article ata are legislative
and quasi-legislative meetings). However, the SC found Calera guilty of LIGHT COERCIONS (art 287)
instead. Evidence shows that he was guilty of unjust vexation in causing the commotion