Case Digest (G.R. No. 7284)
Facts:
The United States v. Jose Batallones et al., G.R. No. 7284, August 23, 1912, the Supreme Court En Banc, Carson, J., writing for the Court. The United States (plaintiff and appellee) prosecuted Jose Batallones (justice of the peace), and policemen Maximo Cuadro and Isaac Demo (defendants and appellants) for detencion arbitraria (illegal detention) under Article 200 of the Penal Code.On or about December 5, 1909, two secret-service agents of the Bureau of Internal Revenue, Apolonio Gumarang and Inocencio Reyes, were in Cabuyao, Laguna, on official business. A local woman observed them behaving furtively near the market, approached them, and they slipped away. She reported her suspicions to the two policemen on duty, who questioned the men and demanded their cedulas. The agents could not produce cedulas and attempted to show English-language documents identifying their purpose. The policemen, unable to read the papers and alarmed by recent local robberies and the agents' conduct, arrested them and brought them to Justice Batallones at his home that evening.
The justice glanced at the papers and—without further inquiry, without taking testimony, and without seeking assistance to verify the documents—ordered the two men detained in the municipal jail until further orders. The agents were held overnight and released the next morning after the municipal treasurer furnished information confirming their identity and employment.
At trial the judge convicted all three accused of detencion arbitraria under Article 200 and imposed the statutory maximum fine of 3,250 pesetas on each. On appe...(Subscriber-Only)
Issues:
- Were policemen Maximo Cuadro and Isaac Demo criminally liable under Article 200 of the Penal Code for arresting and detaining the two secret-service agents?
- Was Justice Jose Batallones criminally liable under Article 200 for ordering the continued detention of the arrested agents w...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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