G.R. No. L-3971

THE UNITED STATES, plaintiff-appellee, vs. HILARIO BRAGANZA AND MARTIN SALIBIO, defendants-appellants.

February 3, 1908

FACTS:
Hilario Braganza, a municipal councilor, and Martin Salibio, a barrio lieutenant, both public officials, detained Father Feliciano Gomez, a Roman Catholic priest. Father Gomez had gone to a church to say mass, but a group of Aglipayano women violently prevented him, leading to a disturbance. The defendants seized Father Gomez inside the church, declared him under arrest, and took him to the municipal building, where he was detained. The detention lasted less than half an hour before he was released on verbal recognizance. The ownership and possession of the chapel were disputed between the Roman Catholic and Aglipayano Churches, a common controversy at the time. The court below found the defendants guilty.

ISSUE:
Whether the detention of Father Feliciano Gomez by Hilario Braganza and Martin Salibio, as public officials, constituted the crime of arbitrary detention under Article 200 of the Penal Code.

RULING:
Yes. The Supreme Court affirmed the lower court’s judgment, finding Hilario Braganza and Martin Salibio guilty of arbitrary detention. The Court adopted the Attorney-General’s position, holding that the defendants, as public officials, detained Father Gomez without being authorized by law or general regulations. The detention was arbitrary because Father Gomez had not committed any crime; on the contrary, he was the victim of coercion. Thus, the elements of arbitrary detention under Article 200 of the Penal Code were met.