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Valenton, Francis Angelo T.

Criminal Law 2

1S

Madsali vs. People (G.R. No. 179570)

Facts: The petitioners are Egap Madsali, Sajiron Lajim and Maron Lajim. The respondent is the
People of the Philippines. In the case at bar, on or about the 2nd day of July, 1994 in the morning
up to December 15, 1994, in Bataraza, Palawan, the petitioners conspired together with the use
of force, violence and intimidation, feloniously take and detain AAA, an unmarried woman
under 15 years of age in the house of Egap Madsali. The herein petitioner Sajiron is the one who
personally took the said victim by threatening to kill her with bolo. Sajiron and Maron also raped
said victim while in captive, while Egap did not. This caused AAA of her liberty all against her
will and as a result of that illegal detention of that said AAA was not able to go home to her
mother for a period of more than five months. The RTC finds Sajiron and Maron guilty of
abduction with rape. While Egap and Sajiron are guilty of serious illegal detention.

Issue: Are the appellants guilty of serious illegal detention.

Held: The Supreme Court said that the appellants are guilty of serious illegal detention. With
the exception for one petitioner. Egap and Sajiron are guilty of serious illegal detention. It is
because all the elements under Article 267 of the RPC were present. These are: “(1) the offender
is a private individual; (2) he kidnaps or detains another, or in any manner deprives the latter of
his liberty; (3) the act of detention or kidnapping must be illegal; and (4) in the commission of
the offense any of the following circumstances is present: (a) the kidnapping or detention lasts
for more than three days; (b) it is committed by simulating public authority; (c) serious physical
injuries are inflicted upon the person kidnapped or detained or threats to kill him are made; or (d)
the person kidnapped and kept in detained is a minor, the duration of his detention is immaterial”