People v. Olimpio de Peralta

Summary

This 1921 criminal case involved Olimpio de Peralta, who succeeded Cecilio Toledo as president of the Philippine Marine Union and entered Toledo's room to retrieve union property. The trial court convicted Peralta of trespass to dwelling under Article 491 of the Penal Code. However, the Supreme Court reversed the conviction, establishing an important legal distinction between entering without permission versus entering against prohibition. The Court held that trespass to dwelling requires entrance against the express or presumed will of the occupant, not merely without permission. The decision clarified that lack of permission should not be confused with prohibition, and that familiarity among association members, daytime entry, and an unlocked door suggested no express prohibition existed.