THE UNITED STATES, complainant-appellee, vs. GREGORIA HERRERA, ET AL., defendants-appellants.
FACTS:
The defendants, Gregoria Herrera and others, were convicted by the trial court of the crime of detencion ilegal (illegal detention) for allegedly detaining a 17-year-old girl named Marcelina Aralar. The alleged detention occurred between July 7 and 18 at a house located at No. 49 Calle Arranque, Manila. The evidence, however, established that during this period, Marcelina Aralar frequently left the house, both in the company of the defendant Gregoria and alone.
ISSUE:
Whether the defendants are guilty of the crime of illegal detention under Article 481 of the Penal Code, given that the alleged victim was not deprived of her liberty during the period in question.
RULING:
The Supreme Court reversed the judgment of conviction and acquitted the defendants. The Court held that for illegal detention to exist, the victim must be deprived of liberty. The evidence showed that Marcelina Aralar was free to leave the house and did so frequently, both accompanied and unaccompanied, during the alleged period of detention. Therefore, the essential element of deprivation of liberty was absent. This case was deemed indistinguishable from prior precedents (United States vs. Quevengco, G.R. No. 1208, and United States vs. Chu Cheng, G.R. No. 1112). The acquittal was without prejudice to the filing of separate complaints for other possible offenses, such as corruption of minors against Gregoria and estupro (seduction) against the defendant Arsenio. Costs were adjudged de oficio.
