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Valenton, Francis Angelo T.

Criminal Law 2


Astorga vs. People (G.R. No. 154130)

Facts: The petitioner is Benito Astorga. The respondent is the People of the Philippines. In the
case at bar, a team of DENR employees went to Samar to conduct intelligence gathering. The
team, while gathering intelligence regarding the governments campaign against illegal logging
sought to investigate a construction of two boats. There, they met the petitioner Mayor Astorga.
The latter summoned the team leader Simon, and as the latter approach Astorga, he was slapped
by him twice on the shoulder. The petitioner then threaten Simon that he can declare it as a
misencounter. Later on, the petitioner summoned reinforcements and made them surround the
intelligence team, with the guns pointed at them. Simon asked if they could go home, but the
petitioner did not allow them. Instead, they were brought to Daran where the house of the
petitioner is located. While in petitioners house, they were allowed to go down from the house,
but not allowed to leave the Barangay. The Sandigangbayan found the petitioner mayor guilty of
arbitrary detention. The petitioner filed a motion for reconsideration based on the allegation that
mere presence of armed men does not qualify as competent evidence to prove that fear was
instilled in the mind of the team members.

Issue: Is the appellant guilty of grave coercion or arbitrary detention

Held: The Supreme Court said that the appellant is not guilty of the crime of grave coercion.
They are guilty of the crime of arbitrary detention. The herein petitioner is a public officer who
abused his office in depriving the offended party of their liberty. All the elements necessary for
the crime of arbitrary detention are present.