Title
People vs. Galang
Case
G.R. No. 25350
Decision Date
Jul 26, 1926
In 1923, Venancio Galang and accomplices abducted and attempted to rape Iluminada Caparas in Malolos. Galang’s intoxication defense was partially accepted, but his penalty was increased to 14 years, 8 months, and 1 day due to his active role.

Case Digest (G.R. No. 219510)
Expanded Legal Reasoning Model

Facts:

Parties Involved:
  • Plaintiff and Appellee: The People of the Philippine Islands
  • Defendants: Felipe Cruz, Eustaquio Santos, Eugenio Capili, and Venancio Galang (appellant)

Incident Details:

  • Date and Time: October 29, 1923, around 7:00 AM
  • Location: Malolos, Bulacan
  • Victim: Iluminada Caparas, a 25-year-old woman

Sequence of Events:

  • Abduction:
    • Venancio Galang seized Iluminada Caparas while she was on her way to the public market.
    • Felipe Cruz assisted Galang in overcoming her resistance and dragging her into an automobile parked in front of the market.
  • Transportation:
    • The chauffeur, Eustaquio Santos, drove the car toward the Calanate bridge.
    • During the ride, Felipe Cruz embraced and kissed Iluminada repeatedly, taking other liberties with her person.
  • Crossing the River:
    • Upon reaching the bridge, the accused carried Iluminada into a banca (boat) owned by Eugenio Capili.
    • Despite her vigorous resistance, Felipe Cruz held and embraced her while Capili and Galang rowed the banca across the Calanate River.
  • Attempted Rape:
    • After reaching the other side of the river, Iluminada was taken to a hut.
    • Felipe Cruz threw her to the floor and attempted to rape her while Galang stood guard outside.
    • Cruz was forced to stop when Galang warned him of approaching policemen.
  • Arrest:
    • Cruz and Galang were immediately arrested by the policemen.
    • Eustaquio Santos and Eugenio Capili were apprehended later.

Trial Proceedings:

  • Felipe Cruz pleaded guilty and was sentenced to 14 years, 8 months, and 1 day of reclusion temporal.
  • Eustaquio Santos was acquitted.
  • Venancio Galang and Eugenio Capili were found guilty.
    • Galang was sentenced to 12 years and 1 day of reclusion temporal.
    • Capili was sentenced to 8 years and 1 day of prision mayor.
  • Only Galang appealed the judgment.

Defense Argument:

  • Galang’s counsel claimed he was intoxicated during the crime and did not know what he was doing.

Issues:

  • Whether Venancio Galang’s intoxication at the time of the crime absolves him of criminal liability or mitigates his penalty.
  • Whether the penalty imposed on Galang by the trial court was appropriate.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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