G.R. No. L-3699
THE UNITED STATES, plaintiff-appellee, vs. BENITO CUSI, appellant.
March 18, 1908

FACTS:
In the early morning of March 19, 1906, Benito Cusi, the chief of municipal police of Bauan, Batangas, along with other policemen, went to the house of Mariano Macaraig in Natunuan, San Jose, to arrest him based on reports that he was involved in a robbery committed the previous night in Dagatan.

Upon finding Macaraig asleep, Cusi woke him, dragged him out of his room, and began to hit him with the butt end of his revolver. Outside the house, Cusi continued hitting Macaraig with a rifle, and when Macaraig fell into a ditch, Cusi slapped and kicked him. Another policeman, Juan Corona, also struck Macaraig with a bolo. Macaraig was then bound with a bamboo rope, taken to the barrio of San Mariano, and further maltreated and exposed to the sun until noon. All these acts of violence and ill-treatment were done to compel Macaraig to confess his guilt as a robber.

Macaraig’s wife, Honorata Arellano, a companion, Domingo Atienza, and barrio lieutenant Francisco Mitra witnessed parts of the maltreatment. A municipal physician examined Macaraig a few days later and found several bruises and a circular wound, though not serious.

The provincial fiscal filed a complaint for coercion against Benito Cusi and Juan Corona. The trial judge found Cusi guilty and sentenced him to six months of arresto mayor and a fine of 1,500 pesetas, while Corona was acquitted. Cusi appealed the judgment, arguing, among other things, that the court erred in overruling a demurrer based on double jeopardy and denying his claim that Macaraig’s injuries might have been inflicted elsewhere.

ISSUE:
1. Was the appellant, Benito Cusi, correctly convicted of the crime of coercion?
2. Did the trial court err in overruling the demurrer based on double jeopardy?

RULING:
The Supreme Court affirmed the judgment of the trial court.

1. On the conviction for coercion: The Court found that the crime of coercion, defined by Article 497 of the Penal Code, was fully proven. The evidence established that Benito Cusi, through violence and ill-treatment, compelled Mariano Macaraig to confess against his will. The detailed testimonies of Macaraig, his wife, his companion, and the barrio lieutenant, along with the corroborating medical examination, constituted substantial and uniform proof of Cusi’s culpability. The defense’s denials, contradictory witness statements, and attempts to attribute the injuries to other sources were deemed incompatible with the prosecution’s evidence and the existence of the physical bruises. The Court stated that even if Macaraig had been later maltreated elsewhere, it would not negate Cusi’s independently proven actions.

2. On the double jeopardy claim: The Court found no error in the trial court’s overruling of the demurrer. The record did not show that a regular trial had ever been held in the justice of the peace court for the same offense; it merely indicated a postponement of the hearing. Therefore, there was no legal basis to invoke double jeopardy.

Accordingly, Benito Cusi’s conviction for coercion was upheld, with the penalty of six months of arresto mayor, a fine of 1,500 pesetas, and payment of costs.