G.R. No. L-8332; November 13, 1913
THE UNITED STATES, plaintiff-appellee, vs. PIO MERCADO, TOMAS MERCADO, and CATALINO MERCADO, defendants-appellants.

FACTS:
The defendants, Pio Mercado, Tomas Mercado, and Catalino Mercado, were charged with the crime of coaccion (coercion) in the Court of First Instance of Bulacan. The complaint alleged that on December 22, 1911, in Baliuag, Bulacan, the defendants, without legitimate authority and by means of violence or force upon the person of Claro Mercado, prevented him from rendering aid to Maria R. Mateo so that Santiago Mercado could maltreat her at his pleasure. After trial, the court found all three defendants guilty and sentenced each to two months and one day of arresto mayor, a fine of 325 pesetas (with subsidiary imprisonment in case of insolvency), and to pay a share of the costs. The defendants appealed, assigning four errors.

ISSUE:
1. Whether the trial court erred in overruling the objection to a question aimed at impugning the character of a defense witness (Santiago Mercado) by asking about prior convictions for assault.
2. Whether the trial court erred in finding that the crime was committed and that the accused are responsible.
3. Whether the trial court erred in sentencing the accused.
4. Whether the trial court erred in not allowing the accused to testify in their own behalf after they offered to do so.

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

1. On the first assignment of error: The Court held that the trial court did commit an error in overruling the objection to the question regarding the witness Santiago Mercado’s prior convictions for assault. Under Section 342 of Act No. 190 (the Code of Civil Procedure), a witness’s credibility may only be impeached by showing: (a) contradictory statements, or (b) bad general reputation for truth, honesty, or integrity. A witness may also be impeached by showing conviction of a “high crime.” The question here did not fall under any of these permissible methods, as assault is not generally considered a “high crime” (defined as acts nearly allied and equal in guilt to felonies). However, the Court ruled this error was not prejudicial to the defendants. The evidence, even without the improperly admitted testimony, was sufficient to establish that Santiago Mercado assaulted Maria R. Mateo on the occasion in question, which was a central fact necessary to prove the defendants’ coercion. Therefore, the error did not affect the outcome.

2. On the second and third assignments of error: The Court found these assignments raised purely questions of fact. After a careful examination of the evidence, the Court was convinced beyond a reasonable doubt that the defendants were guilty as charged. The conclusions of fact reached by the trial court were upheld.

3. On the fourth assignment of error: The record showed that after the defense presented its sole witness (Santiago Mercado), the accused stated that if they were to testify, they would testify in the same manner as he did. The Court held that allowing such testimony would have been merely cumulative and would not have added anything material to exculpate the defendants. Therefore, no reversible error was committed.

In conclusion, the guilt of the appellants was proven beyond a reasonable doubt, and the sentence of the lower court was affirmed in its entirety.