Title
Caisip vs. People
Case
G.R. No. L-28716
Decision Date
Nov 18, 1970
Gloria Cabalag, cultivating disputed land, was forcibly removed by defendants during a lawful grace period, leading to their conviction for grave coercion.
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Case Digest (G.R. No. L-28716)

Facts:

Background of the Case:

  • The complainant, Gloria Cabalag, is the wife of Marcelino Guevarra, who cultivated a parcel of land known as Lot 105-A of Hacienda Palico in Nasugbu, Batangas. The land was previously tenanted by Gloria's deceased father. Hacienda Palico is owned by Roxas y Cia and administered by Antonio Chuidian, with Felix Caisip as the overseer.

Prior Litigations:

  • On December 23, 1957, Marcelino Guevarra filed an action with the Court of Agrarian Relations seeking recognition as a lawful tenant of Lot 105-A. The court dismissed the case on February 22, 1958, stating it lacked jurisdiction. Guevarra appealed to the Supreme Court, but the appeal was dismissed on April 10, 1958.
  • On May 17, 1958, Roxas y Cia filed a forcible entry case against Guevarra in the justice of the peace court of Nasugbu. The court ruled in favor of Roxas y Cia on May 2, 1959, ordering Guevarra to vacate the lot and pay damages. A writ of execution was issued on June 6, 1959, and possession of the land was delivered to Roxas y Cia through Felix Caisip.

Incident on June 17, 1959:

  • On June 15, 1959, a dispute arose between Gloria Cabalag and Felix Caisip over the cutting of sugar cane on Lot 105-A. The next day, Gloria allegedly re-entered the lot and refused to leave, leading to her being charged with grave coercion and unjust vexation.
  • On June 17, 1959, Gloria was seen weeding the ricefield on Lot 105-A. Caisip approached her and demanded she leave, but she refused, claiming she and her husband had rights to the land. Caisip then sought the help of police officers Ignacio Rojales and Federico Villadelrey, who forcibly dragged Gloria away, tearing her clothes in the process.

Issue:

  1. Whether the acts of the defendants were justified under Article 429 of the New Civil Code.
  2. Whether the 20-day period of grace given to Gloria and her husband to vacate Lot 105-A was valid and lawful.
  3. Whether the elements of the crime of grave coercion are present in the case.
  4. Whether the defendants are guilty of grave coercion.

Ruling:

The Supreme Court affirmed the decision of the Court of Appeals, convicting the defendants of grave coercion. The Court held that:

  • The defendants' actions were not justified under Article 429 of the New Civil Code, as Gloria was not unlawfully invading or usurping the property.
  • The 20-day period of grace granted by the sheriff was valid, and Gloria's act of weeding the ricefield did not constitute a criminal offense.
  • The elements of grave coercion were present, as the defendants used violence to prevent Gloria from doing something not prohibited by law (weeding and staying on the lot) and compelled her to leave against her will.
  • All three defendants, including Caisip, were guilty of grave coercion, with Caisip being a co-conspirator and principal by induction.

Ratio:

  1. Justification Under Article 429 of the Civil Code: The Court ruled that Article 429, which allows the use of reasonable force to repel unlawful invasion or usurpation, did not apply because Gloria was not unlawfully invading the property. She was merely exercising her right to remain on the lot during the 20-day grace period.
  2. Validity of the 20-Day Grace Period: The Court found that the 20-day period granted by the sheriff was lawful and binding, as it was granted with the implied consent of the hacienda owner's representative, Felix Caisip.
  3. Elements of Grave Coercion: The Court held that the defendants used violence to prevent Gloria from performing a lawful act (weeding and staying on the lot) and compelled her to leave against her will, satisfying the elements of grave coercion under Article 286 of the Revised Penal Code.
  4. Guilt of the Defendants: The Court found that all three defendants were guilty of grave coercion. Caisip, though he did not personally use violence, was responsible for initiating the coercion by seeking the help of the police officers, who acted on his behalf.

The Court also noted the presence of aggravating circumstances, including abuse of superior strength and disregard of the respect due to Gloria as a woman. The penalties imposed were in accordance with the law.


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