Title
People vs. Reyes
Case
G.R. No. L-7712
Decision Date
Mar 23, 1956
Defendants accused of coercion in the seizure of a passenger jeep are charged with unjust vexation instead, as the court determines that violence is not an element of the offense.
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Case Digest (G.R. No. L-7712)

Facts:

  • The case is People vs. Reyes, G.R. No. L-7712, decided on March 23, 1956.
  • The plaintiff-appellant is the People of the Philippines; the defendants-appellees are Bernardo Reyes and Mariano Reyes.
  • On August 26, 1953, the City Fiscal filed an information in the Municipal Court of Manila, accusing the Reyes brothers of coercion.
  • The accusation stated that the defendants unlawfully seized a passenger jeep belonging to Agustin Blasco through deceit and misrepresentation to settle Blasco's debt.
  • Despite multiple demands for the return of the jeep, the defendants refused, causing damage to the owner.
  • The Municipal Court dismissed the information, stating it did not allege violence, a requirement for coercion under Article 287 of the Revised Penal Code.
  • The dismissal was upheld by the Court of First Instance of Manila, leading the prosecution to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the prosecution, reversing the lower court's dismissal.
  • The Court held that the coercion alleged fell under the second paragraph of Article 287, which does not require violence.
  • The facts in the information were found to constitute unjust vexation.
  • The Court determined that th...(Unlock)

Ratio:

  • The Supreme Court interpreted Article 287 of the Revised Penal Code, clarifying that the first paragraph involves coercion with violence, while the second paragraph addresses coercion and unjust vexation without violence.
  • The absence of violence in the allegations allowed the offense to be classified under the second par...continue reading

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