Case Summary (G.R. No. 1046)

Waiver of Defects in the Complaint

• The failure to allege that the defendant was a member of the Constabulary in a prosecution for a statute applicable only to Constabulary officers is waived if not objected to during the trial.
• The defendant did not raise this objection at trial, which could have been addressed through a demurrer.

Facts of the Case

• On July 11, 1902, Felix Manalang, a Constabulary member, sought a revolver from Tomas Lacsamana, who denied possession.
• Manalang and his companions tortured Lacsamana by forcing him to swallow water through a cane, resulting in a broken tooth.
• Lacsamana was unlawfully detained for over 24 hours and was only released after his wife paid 15 pesos, demanded by Manalang as a condition for his release.

Evidence of Guilt

• The evidence presented in the case established that Manalang directly participated in the crime.
• The unlawful imprisonment and torture of Lacsamana, along with the demand for money, were fully supported by witness testimonies.
• The defendant's denial of the charges was unsupported by any evidence.

Legal Deficiencies in the Information

• The defense argued that the information was defective for not stating that Manalang was a Constabulary member, which they claimed was essential for the crime's existence.
• This objection was deemed unavailing as it was not raised during the trial, and the defendant di...continue reading