G.R. No.

123101

November 22, 2000

PEOPLE OF THE PHILIPPINES, plaintiff-appellee,

vs.
TITING ARANAS @ TINGARDS/RONNIE, ANGELO PARACUELES, JUAN VILLA @
JUANTOY, ELMER MANALILI, ET AL. accused.
ELMER MANALILI, accused-appellant.
FACTS:
On or about December 15, 1992, in the seawaters of Ubay, Bohol, Philippines, the
accused-appellants Titing Aranas. Angelo Paracueles, Juan Villa, and Elmer Manalili, with intent
to gain, and by means of violence seize by boarding a passenger sea vessel M/V J & N Princess
with 19 officers and crew members. While on board of said vessel, accused seized its radio and
subsequently demanded and divested its passengers cash, valuables, and equipment. On the
occasion of said piracy, accused committed the crime of physical injuries against Ernesto
Magalona, the quarter master.
The case proceeded only against Manalili since all others remain at large.
ISSUE:
Whether or not the prosecution failed to prove beyond reasonable doubt that he was one
of the pirates in this case
RULING:
Yes. Prosecution witness Gervacio Uy identified the two armed men, who initially
pointed a gun at him in the comfort room at the lower deck, and who ordered him to go with
them to the radio room at the third or upper deck, as Titing Aranas and Angelo Paracueles. On
the other hand, prosecution witness Ernesto Magalona who saw Gervacio Uy and the two armed
men as they passed by the second deck on their way to the third deck, identified one of those two
armed men as appellant Elmer Manalili. Where eyewitnesses contradict themselves on a vital
question, such as the identity of the offender, the element of reasonable doubt is injected and
cannot be lightly disregarded. The identity of the offender, like the crime itself must be proven
beyond a reasonable doubt. In the case at bench, there is no positive identification of the
appellant inasmuch as prosecution eyewitnesses Uy and Magalona contradicted themselves on
the identity of the alleged offender.

G.R. No. 154130

October 1, 2003

BENITO ASTORGA, petitioner,

vs.
PEOPLE OF THE PHILIPPINES, respondent.
FACTS:
On September 1, 1997, Regional Special Operations Group (RSOG) of the Department of
Environment and Natural Resources (DENR), Tacloban City sent a team to the island of Daram,
Western Samar to conduct intelligence gathering and forest protection operations in line with the
governments campaign against illegal logging. The team stopped at Brgy. Bagacay where they
saw two yacht-like boats being constructed. En route to Brgy. Manungca, Sta. Rita, Samar, the
team spotted two more boats being constructed. There, they met Mayor Benito Astorga. A banca
arrived bearing ten (10) men, some of them dressed in fatigue uniforms. The team was brought to
a house where they were told that they would be served dinner. The team had dinner with Mayor
Astorga. After dinner, Militante, Maniscan and SPO1 Capoquian were allowed to go down from
the house, but not to leave the barangay. On the other hand, SPO3 Cinco and the rest just sat in
the house until 2:00 a.m. when the team was finally allowed to leave.
ISSUE:
Whether or not the accused is guilty for the crime of arbitrary detention
RULING:
Yes. The elements of arbitrary detention are: (a) that the offender is a public officer or
employee; (b) that he detains a person; (c) that the detention is without legal grounds. Petitioner,
at the time he committed the acts was then Mayor of Daram, Samar is not disputed. Hence, the
first element that the offender is a public officer or employee, is undeniably present. He admitted
that his acts were motivated by his "instinct for self-preservation" and the feeling that he was
being "singled out." The detention was thus without legal grounds, thereby satisfying the third
element enumerated above. The prevailing jurisprudence on kidnapping and illegal detention is
that the curtailment of the victims liberty need not involve any physical restraint upon the
victims person. In the case at bar, the restraint resulting from fear is evident. Inspite of their
pleas, the witnesses and the complainants were not allowed by petitioner to go home.

G.R. No. 134503 July 2, 1999

JASPER AGBAY, petitioner,
vs.
THE HONORABLE DEPUTY OMBUDSMAN FOR THE MILITARY, SPO4 NEMESIO
NATIVIDAD, JR. and SPO2 ELEAZAR M. SOLOMON, respondent.
FACTS:
On September 7, 1997, petitioner Jasper Agbay, together with Sherwin Jugalbot, was
arrested and detained at the Liloan Police Station, Metro Cebu for an alleged violation of R.A.
7610, the "Special Protection of Children Against Child abuse, Exploitation and Discrimination
Act. On September 26, 1997, petitioner filed a complaint for delay in the delivery of detained
persons against private respondents SPO4 Nemesio Natividad, Jr., SPO2 Eleazar M. Salomon
and other unidentified police officers before the Office of the Deputy Ombudsman for the
Visayas.
ISSUE:
Whether or not the filing of the complaint with the Municipal Trial Court constitutes to a
"proper judicial authority"
RULING:
Yes. Art. 125 of the Revised Penal Code is intended to prevent any abuse resulting from
confining a person without informing him of his offense and without permitting him to go on
bail. More specifically, it punishes public officials or employees who shall detain any person for
some legal ground and shall fail to deliver such person to the proper judicial authorities within
the periods prescribed by law. Furthermore, upon the filing of the complaint with the Municipal
Trial Court, the intent behind Art. 125 is satisfied considering that by such act, the detained
person is informed of the crime imputed against him and, upon his application with the court, he
may be released on bail.

G.R. No. 121917 July 31, 1996

ROBIN CARIO PADILLA, accused-appellant,
vs.
COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, plaintiff-appellees.
FACTS:
Apellant Robin C. Padilla was charged with violation of P.D. No. 1866 for illegal
possession of firearms punishable by reclusion temporal maximum to reclusion perpetua.
Pending trial, appellant was released on bail. Thereafter, appellant was convicted as charged and
meted an indeterminate penalty of 17 years 4 months and 1 day of reclusion temporal to 21 years
of reclusion perpetua. He appealed to public respondent Court of Appeals, but judgment was
rendered affirming his conviction.
-----eto lang talaga ang facts ng case (from lawphil)---- HONESTO PROMISE
ISSUE:
Whether or not appellant is entitled to bail
RULING:
No. Bail is either a matter of right, or of discretion. It is a matter of right when the offense
charged is not punishable by death, reclusion perpetua or life imprisonment. In this case,
appellant was convicted of a crime punishable by reclusion perpetua. Applying the aforequoted
rule, appellant is not entitled to bail as his conviction clearly imports that the evidence of his
guilt is strong. And contrary to appellant's asseveration, a summary hearing for his bail
application for the sole purpose of determining whether or not evidence is strong is unnecessary.
Indeed, the extensive trial before the lower court and the appeal before respondent court are more
than sufficient in accomplishing the purpose for which a summary hearing for bail application is
designed.