Title
People vs Manalang
Case
G.R. No. 1046
Decision Date
Mar 21, 1903
Constabulary member Felix Manalang tortured, detained, and extorted money from Tomas Lacsamana in 1902, violating Act No. 175; conviction upheld despite procedural defect.
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Case Digest (G.R. No. 1046)

Facts:

  1. Incident Overview:
    On July 11, 1902, Felix Manalang, a member of the Constabulary forces in Pampanga, along with two companions, went to the house of Tomas Lacsamana in Bacolor to search for a revolver. Lacsamana denied possessing the weapon.

  2. Torture and Detention:
    Lacsamana was seized, stretched on the ground, and tortured by being forced to swallow water through a piece of cane, resulting in the breaking of one of his teeth. He was then taken to a police station in Santa Rita and detained until the night of July 12, 1902.

  3. Extortion of Money:
    On July 12, 1902, Manalang, through his companion Eugenio Tayo, demanded 15 pesos from Lacsamana's wife, Ines Garcia, as a condition for Lacsamana's release. The money was loaned by Felipe Garcia and delivered to Manalang. Lacsamana was released only after the payment was made.

  4. Witnesses and Reporting:
    The delivery of the money was witnessed by Ines Garcia, Eugenio Tayo, and Catalino Lacsamana. Pedro de Jesus, a member of the municipal council, reported the incident to the municipal president, who then informed the provincial fiscal, leading to the filing of charges.

  5. Legal Basis:
    The acts committed by Manalang constituted the offense defined and punished by Section 19 of Act No. 175, passed on July 18, 1901.

Issue:

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Ruling:

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Ratio:

  1. Guilt Established by Evidence:
    The evidence fully established that Manalang, as a member of the Constabulary, unlawfully detained and tortured Tomas Lacsamana, extorted 15 pesos from his wife, and held him in custody until the money was paid. These acts constituted the crime defined under Section 19 of Act No. 175.

  2. Defective Information Not Fatal:
    The failure of the information to explicitly state that Manalang was a member of the Constabulary at the time of the offense did not vitiate the proceedings. The defect was not raised during the trial, and Manalang did not deny his status as a Constabulary member. Therefore, the objection raised on appeal was deemed insufficient to annul the proceedings or reverse the judgment.

  3. Complex Nature of the Offense:
    The offense under Section 19 of Act No. 175 is complex, encompassing various acts that constitute the crime. The information adequately described these acts, and the failure to specify Manalang's status did not prejudice his defense or the integrity of the proceedings.


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