G.R. No. L-9294; March 30, 1914
THE UNITED STATES, plaintiff-appellee, vs. EULOGIO SANCHEZ, defendant-appellant.

FACTS:
Eulogio Sanchez, a municipal policeman of Caloocan, Rizal, was charged with illegal detention under Article 200 of the Penal Code. The accusation stemmed from his arrest and detention of Benigno Aranzanso on the morning of August 13, 1912. Sanchez arrested Aranzanso in a cockpit and detained him in the municipal jail until just before nightfall of the same day, when he was released by order of the municipal president. The arrest was made without a warrant because the day was a legal holiday and the matter had not yet been reported to the justice of the peace.

The arrest was carried out pursuant to orders from the acting chief of police (a sergeant). The police had information that a robbery had occurred on a boat in the Maypajo River two nights prior, and a suspect was described as the son of one “Eto” who had been in a billiard room on the night of the crime. Furthermore, on the night of August 12, the Constabulary was investigating a separate robbery in a billiard room, and information indicated that Benigno Aranzanso had been present there and had left hurriedly. Based on these reports and because Aranzanso matched the general description, the sergeant ordered all patrolmen, including Sanchez, to locate and arrest Aranzanso for the purpose of having him identified by the victims. Aranzanso was released before the identification could take place.

ISSUE:
Whether the arrest and detention of Benigno Aranzanso by policeman Eulogio Sanchez constituted the crime of illegal detention.

RULING:
No. The Supreme Court reversed the judgment of the Court of First Instance and acquitted the defendant.

The Court held that Sanchez did not commit illegal detention. He acted in compliance with the lawful orders of his superior, the sergeant of police, who had reasonable grounds to suspect Aranzanso’s involvement in the robberies based on the information received. The detention was justified as an administrative measure for the purpose of identifying a suspect, a duty inherent to police functions. The legality of such a detention does not depend on the subsequent establishment of the fact of a crime, but on whether the officer had reasonable grounds to infer from the circumstances that a crime had been committed and that the detained person was implicated. Citing Spanish Supreme Court jurisprudence, the Court ruled that compelling a person to appear for identification based on reasonable suspicion is a justified police measure and does not constitute illegal detention.

The defendant was acquitted, with costs de officio.