Case Summary (G.R. No. 87318)
Facts of the Case
On October 29, 1923, Iluminada Caparas was on her way to the public market when she was abducted by Venancio Galang, who forcibly carried her to an automobile parked nearby. Felipe Cruz, assisting Galang, helped subdue the victim and ordered the chauffeur, Eustaquio Santos, to drive towards Calanate Bridge. During the drive, Cruz engaged in inappropriate conduct towards Caparas. Upon reaching the bridge, the accused transferred Caparas to a banca owned by Eugenio Capili and rowed across the river with her, despite her resistance. Once on the other side, Cruz attempted to rape her but was interrupted by the approach of two policemen, leading to the arrest of Cruz and Galang, while Santos and Capili were apprehended later.
Lower Court Proceedings
The case was brought before the Court of First Instance in Bulacan, where Felipe Cruz pleaded guilty and received a sentence of fourteen years, eight months, and one day of reclusion temporal. Eustaquio Santos was acquitted, while Venancio Galang and Eugenio Capili were found guilty. Galang was sentenced to twelve years and one day of reclusion temporal, and Capili to eight years and one day of prision mayor. Only Galang appealed the judgment.
Appellant’s Argument
Galang's counsel argued that he was intoxicated at the time of the commission of the crime, which impaired his understanding of his actions. The court noted that while the extent of Galang's intoxication was questionable due to his active participation in the crime, the claim was nonetheless considered as potentially extenuating.
Court’s Decision
After evaluating the circumstances of the case, the court decided to impose an increased penalty on the appellant, modifying the previous judgment. It concluded that while the intoxication could serve as a mitigating factor, it did not sufficiently counterbalance the aggravating circumstance of abuse of superiority that occurred during the commission of the crime. Thus, the penalty was adjusted to fourteen years, eight month
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Case Background
- The case involves the crime of abduction by violence and attempted rape.
- The defendants include Felipe Cruz, Eustaquio Santos, Eugenio Capili, and Venancio Galang, the appellant.
- The incident took place on October 29, 1923, in Malolos, Bulacan.
- Iluminada Caparas, a 25-year-old woman, was the victim of the abduction.
Incident Details
- At approximately 7 o'clock in the morning, Iluminada Caparas was seized by Venancio Galang while walking to the public market.
- Felipe Cruz was present beside the automobile and aided Galang in forcibly dragging Caparas into the vehicle.
- Eustaquio Santos, the chauffeur, was ordered to drive towards Calanate bridge.
- During the ride, Felipe Cruz engaged in inappropriate physical contact with Caparas, including repeated embraces and kisses.
Actions Upon Arrival
- Upon reaching the bridge, the accused carried Caparas from the car to a banca owned by Eugenio Capili.
- Despite her vigorous resistance, Cruz continued to hold and embrace her while Capili and Galang rowed the banca across the Calanate River.
- After reaching the opposite bank, Caparas was taken into a hut w