GR 1229; (August, 1903) (Digest)
March 7, 2026GR 1278; (August, 1903) (Digest)
March 7, 2026G.R. No. 1208 : August 6, 1903
THE UNITED STATES, complainant-appellee, vs. JOSE QUEVENGCO, defendant-appellant.
FACTS:
Sotera Jico was taken from her house by the defendant’s servants and a Constabulary soldier, compelled against her will to go with them, accompanied by her aunt, to the house of the defendant, Jose Quevengco. She remained in the defendant’s house for three days, during which she worked as a servant, had freedom of movement within the house, and was allowed to leave at times to visit her mother on the same estate, accompanied only by a small child.
ISSUE:
Whether the defendant may be convicted of the crime of coaccion under a complaint specifically charging him with detencion ilegal (illegal detention).
RULING:
The Supreme Court reversed the judgment of the lower court. The facts did not constitute the crime of detencion ilegal because Sotera Jico had freedom of movement during her stay at the defendant’s house. However, the act of compelling her against her will to leave her house and go to the defendant’s house constituted the crime of coaccion under Article 497 of the Penal Code. Since coaccion is necessarily included in the crime of detencion ilegal, the defendant could be validly convicted of coaccion under the complaint for illegal detention, pursuant to General Orders No. 58, Section 29. The aggravating circumstance of sex (Article 10, No. 20 of the Penal Code) was considered. The defendant was found guilty of coaccion and sentenced to six months of arresto mayor, a fine of 325 pesetas, an indemnity of 25 pesos to Sotera Jico, and payment of costs.
