GR L 13020; (December, 1917) (Digest)
G.R. No. L-13020, December 20, 1917
THE UNITED STATES, plaintiff-appellee, vs. JOAQUIN PABALAN, ET AL., defendants. JOAQUIN PABALAN, appellant.
FACTS:
In Calamba, Laguna, a superstitious cult known as “Mina” or “Baycot” operated, deceiving victims into leaving money in exchange for promised gold. Gabriel Bautista, believed to know the location of the cult’s hidden money, was subjected to a search of his house and was taken to the municipal building by order of Joaquin Pabalan, the sergeant of police. There, Bautista was tortured by being suspended with his hands tied to a bamboo pole while standing on a box, which was then removed, leaving him hanging. This was done to force him to confess the whereabouts of the money and to reveal if a certain Adriano was the “voice of the old man.” Bautista maintained he did not know. Although two other policemen were acquitted by the trial court for merely following orders, Pabalan was held directly responsible for ordering the torture.
ISSUE:
Whether Joaquin Pabalan is guilty of the crime of coercion for ordering the torture of Gabriel Bautista to extract a confession, taking advantage of his public position as a police officer.
RULING:
Yes. The Supreme Court found Pabalan guilty of the crime of coercion under Article 497 of the Penal Code, as he, without legal authority and through violence, compelled Bautista to act against his will. The Court emphasized that police officers who abuse their authority and employ barbarous methods deserve no leniency. Since Pabalan took advantage of his public position, the penalty was imposed in its maximum degree. The Court modified the lower court’s judgment, sentencing Pabalan to six months of arresto mayor, with accessory penalties, a fine of ₱650 (or subsidiary imprisonment in case of insolvency), and payment of proportionate costs. The decision underscores that while the law protects police in their legitimate duties, it must equally protect citizens from police abuse.
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