Title
Lee vs. Court of Appeals
Case
G.R. No. 90423
Decision Date
Sep 6, 1991
Branch manager accused of grave coercion for confronting a pregnant complainant over a forged check; Supreme Court acquitted, citing lack of coercion and complainant's voluntary actions.

Case Digest (G.R. No. 90423)

Facts:

Francis Lee v. Court of Appeals, People of the Philippines and Pelagia Panlino de Chin, G.R. No. 90423, September 06, 1991, the Supreme Court First Division, Medialdea, J., writing for the Court.

Petitioner Francis Lee, Branch Manager of Pacific Banking Corporation, was criminally charged by the People with grave coercion under Article 286 of the Revised Penal Code arising from an incident on June 20, 1984 involving complainant Pelagia Paulino de Chin. The prosecution alleged that Lee fetched the pregnant complainant to the bank, confronted her about a purportedly forged cashier’s check, shouted at her with “piercing looks,” threatened to file criminal charges unless she returned the proceeds, and had bank employees and guards watch her while she signed a prepared withdrawal slip and an affidavit and turned over money.

The Metropolitan Trial Court (MTC), Branch 2, Caloocan City, convicted Lee of grave coercion and sentenced him to three months arresto mayor, fined him, and ordered civil damages. The Regional Trial Court (RTC), Branch 129, Caloocan City, modified the MTC judgment: it found Lee guilty only of light coercion under Article 287, sentenced him to 20 days arresto menor, and awarded one-third of the costs. The Court of Appeals, however, by decision dated June 29, 1989, reversed the RTC and reinstated and affirmed the MTC conviction for grave coercion.

Petitioner filed a petition for review on certiorari under Rule 45 to the Supreme Court, ch...(Pro-only)

Issues:

  • Did petitioner’s alleged acts—shouting, “piercing looks,” threats to file charges and the attendant conduct at the bank—constitute grave coercion under Article 286 of the Revised ...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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