G.R. No. L-3860
THE UNITED STATES, plaintiff-appellee, vs. FAUSTINO TREMOYA, defendant-appellant.
February 5, 1908

FACTS:
Faustino Tremoya and his brother Gregorio Tremoya were adverse claimants to a parcel of hemp land with Santiago Puñado. Faustino Tremoya, accompanied by four workmen, visited the disputed land and found Prudencio and Aniceto Rodriguez (employees of Puñado) cutting hemp. Tremoya ordered them to stop. A dispute ensued, during which Prudencio Rodriguez displayed a bolo, and Tremoya responded by drawing his revolver, pointing it at Prudencio, and threatening to shoot him and his companions if they did not leave. The Rodriguez brothers and their companions then departed, leaving Tremoya and his party in possession of the hemp. Tremoya was aware that the Rodriguez brothers were employees of Puñado and were acting under his orders, as they had previously been arrested at the instance of Tremoya’s brother for stealing hemp from the same lot but were acquitted by a justice of peace on the ground that they were merely employees. The Court of First Instance of Ambos Camarines convicted Tremoya of coaccion.

ISSUE:
Whether the appellant’s actions of using violence and intimidation to dispossess individuals from disputed land constitute the offense of coaccion.

RULING:
Yes, the appellant’s actions constitute the offense of coaccion. The Supreme Court affirmed the conviction of Faustino Tremoya. The Court held that Santiago Puñado and his men were in possession of the land under a claim of right. Tremoya’s proper recourse was to assert his title, if any, through legal channels in the courts, rather than resorting to forcible dispossession. The violence and intimidation employed by Tremoya (drawing a revolver and threatening to fire) to drive the employees off the land and obtain possession of the hemp against their will falls squarely within the definition of coaccion as provided in Article 497 of the Penal Code.