Contempt or with insult to public authorities, as an aggravating circumstance under the Revised Penal Code – refers to the circumstance when the offender committed the crime in such a manner.
a. Legal basis
Article 14. Aggravating circumstances. - The following are aggravating circumstances:
2. That the crime be committed in contempt or with insult to the public authorities.
(Revised Penal Code)
2. Contempt or with insult to the public authorities
For the aggravating circumstance of contempt or with insult to public authorities, the offender committed the crime in such a manner.
a. Public authorities
In the 1981 case of People v. Rodil, it was held that public authorities include but not are not limited to persons in authority.
People v. Rodil, En Banc, G.R. No. L-35156, November 20, 1981, Per Makasiar, J.:
• The aggravating circumstance of contempt of, or insult to, public authority under paragraph 2 of Article 14 of the Revised Penal Code can likewise be appreciated in the case at bar.
• The evidence of the prosecution clearly established that Chief of Police Primo Panaligan of Indang was present as he was taking his lunch in the same restaurant when the incident occurred.
• As a matter of fact, the said chief of police was the one who embraced or grabbed the accused from behind, wrested the dagger from him and thereafter brought him to the municipal building of Indang. And appellant admittedly knew him even then as the tow...
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