GR 4580; (September, 1908) (Digest)
G.R. No. 4580
THE UNITED STATES, plaintiff-appellee, vs. SANTIAGO FONTANILLA, defendant-appellant.
September 7, 1908
FACTS:
Santiago Fontanilla went to a tract of land in Magatel, Luna, La Union, where Apolonio de Peralta and other laborers were tilling. A dispute arose over the right to cultivate the land, which Fontanilla claimed as his own. Fontanilla, being the aggressor, captured and tied Peralta and Emetrio Navalta, after driving away the other laborers. He then took his two prisoners to the municipal jail and turned them over to the jailer. Peralta and Navalta were detained for a couple of hours before being released by order of the municipal president or justice of the peace. Fontanilla was not a peace officer, and there was no evidence that Peralta or Navalta had committed any crime that would justify their arrest without a warrant by either a peace officer or a private person. The trial court found Fontanilla guilty under Article 481 of the Penal Code.
ISSUE:
Whether the act of Santiago Fontanilla constitutes unlawful detention under Article 481 (simple detention) or Article 483 (detention for the purpose of turning over to authorities) of the Penal Code.
RULING:
The Supreme Court REVERSED the trial court’s decision, finding Santiago Fontanilla guilty of unlawful detention defined and penalized in Article 483 of the Penal Code. The Court held that the crucial fact that Fontanilla, after apprehending Peralta and Navalta, immediately conducted them to the municipal jail and turned them over to the authorities, takes the offense out of Article 481 (which provides for prision mayor) and brings it within the purview of Article 483. Article 483 specifically covers cases where a person, without sufficient reason, apprehends or detains another in order to turn him over to the authorities. While acknowledging that the penalty prescribed under Article 483 (arresto menor) seemed “hardly adequate” given the circumstances, the Court emphasized its duty to impose the penalty prescribed by law.
Accordingly, Santiago Fontanilla was sentenced to thirty days of arresto menor, to pay a fine of P3,250 pesetas (with subsidiary imprisonment in case of insolvency), and to pay the costs.