G.R. No. 94704 , January 21, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CHERINA DAYON, accused-appellant.

FACTS

Accused-appellant Cherina Dayon was charged with Serious Illegal Detention under an Information dated May 26, 1988. It alleged that on or about April 1, 1988, in Davao City, she willfully, unlawfully, and feloniously detained Marilou Peralta in a bodega for three days (April 1 to April 3, 1988) against the latter’s will, because Peralta refused to sign a promissory note. The detention allegedly caused Peralta, a woman, to be hospitalized. After trial, the Regional Trial Court of Davao City, Branch 15, rendered a decision on June 20, 1990, convicting Dayon and imposing the penalty of Reclusion Perpetua. The trial court’s factual findings, based on the evidence, included: (1) On April 1, 1988, Dayon invited Peralta to go to the Shrine, and upon refusal, to the house of a certain Tulio; (2) At Tulio’s house, Dayon left and returned with five policemen, who took Peralta to the Talomo Police precinct for investigation; (3) Peralta was investigated for over four hours and was pressured to sign a promissory note, which she refused; (4) Peralta was returned to Tulio’s house in the evening without having eaten meals; (5) Peralta’s husband, daughter, and friend pleaded with Dayon to allow Peralta to go home, but Dayon refused, stating she wanted to sue Peralta in court on April 4 and feared Peralta might run away; (6) On April 2, Peralta’s family again pleaded unsuccessfully for her release.

ISSUE

Whether the trial court erred in convicting accused-appellant Cherina Dayon of the crime of Serious Illegal Detention, based on the facts as found.

RULING

The Supreme Court AFFIRMED the trial court’s decision, holding that the prosecution proved the guilt of the accused beyond reasonable doubt. The Court outlined the elements of Serious Illegal Detention under Article 267 of the Revised Penal Code: (1) the offender is a private individual; (2) the offender kidnaps or detains another, or deprives them of liberty; (3) the detention is illegal, not ordered by competent authority or allowed by law; and (4) any of the following circumstances is present: (a) detention lasts more than five days; (b) committed by simulating public authority; (c) serious physical injuries are inflicted or threats to kill are made; or (d) the person detained is a minor, female, or public officer. The Court found all elements present, noting that the detention of a female (Marilou Peralta) for three days was established. It rejected appellant’s arguments that the facts were inconsistent with illegal detention (e.g., visitors were allowed, no report to police, non-inclusion of other possible accused), emphasizing that deprivation of liberty does not require enclosure and can occur if the victim is unable to move freely. The Court upheld the trial court’s credibility assessments of prosecution witnesses and found no reason to disturb them, concluding that the presumption of innocence was overcome by proof beyond reasonable doubt. Costs were imposed against the appellant.