DIGEST - People v. Crisostomo PDF

12. People v.
Crisostomo
G.R. No. L-19034 | 17 February 1923 | Romualdez, J.
Aggy | TOPIC: Abduction & Coercion
Doctrine:
FOR ABDUCTION TOPIC:
Unchaste or lewd designs is an essential element to the crime of abduction. It is the intention to abuse the
abducted woman. Absence of such, the act committed will no longer constitute the crime of abduction, but a
crime against the liberty of the person.
FOR COERCION TOPIC:

For one to be convicted of attempted coercion, the acts of the accused must directly tend to the intended
result of compelling the victim to do acts against his/her will. They must be direct. They must be the beginning
of the execution of the crime, with a direct, rational, and necessary tendency to produce the intended result.
Facts:
SC found defendants guilty of ILLEGAL DETENTION. They held that neither abduction nor coercion is
the crime because the elements of said crimes were not present in this case.
1. Defendants were found guilty by the Court of First Instance of Cavite of the consummated crime of
abduction through violence.
a. PRINCIPALS: Pedro Crisostomo, Lorenzo Alcoba, Casimiro Garde
b. ACCOMPLICES: Segundo Espiritu, Primitivo Alcoba, Bartolome Caguiat
2. On December 26, when Macaria Gabriel (victim) and her aunt, Candida, were walking home, they
met with the defendants. Pedro, Lorenzo, and Casimiro dragged Macaria against her will to a rice
field, while Segundo, Primitvo, and Bartolome seized Candida to prevent her from helping Macaria.
3. Another woman, Gregora Acuña, noticed the incident and went to aid Macaria, while Candida was
able to escape the accomplices, who then, went to their home and reported the matter to Gabriel
(Macaria’s brother).
4. Because of this, the defendants finally released Macaria and Gabriel went after them.
5. Pedro claims that Macaria was not taken against her will, and that they were actually eloping.
Issue + Holding:
1. W/N the crime committed was abduction with violence? – NO.
- It is clear from the evidence that Macaria was taken against her will. Pedro’s claim that
they were eloping was untenable. SC took note of Macaria’s age (30 years old). They held
that being of mature age, Macaria would be more reflexive and cautious in carrying out a
preconceived plan. She would not have eloped in broad daylight.
Notwithstanding the undisputed deprivation of Macaria’s liberty, the crime cannot be

abduction because it was not proven that the acts were with lewd or unchaste
designs. In abduction, unchaste design is an essential element, because without it, the
crime would simply be a crime against the liberty of the victim.
Even if Pedro Crisostomo claimed that the intention for taking Macaria was to marry her,
and though Macaria claimed that Pedro kissed her when she was being taken away, these
do not constitute an unchaste design. An unchaste design would entail an intent of the
accused to abuse the victim. In this case, Pedro’s intent to marry is not unchaste since
they are both consenting adults. Further, the alleged kiss is not lewd given that Pedro
could have done further lewd acts than just kissing, but did not.
It is not necessary to show that unchaste designs were carried out, it is enough that the
existence of the unchaste intention be established. It was not shown in this case.
2. W/N the acts of the defendants would constitute a crime of attempted coercion? – NO.
- It was suggested upon deliberation that the crime may be attempted coercion for Pedro
may have attempted to force Macaria to marry him.
SC held, however, that this was also not established. The more probable hypothesis is
that the accused merely tried to take the victim away from her family in hopes that she
may be persuaded to marry him.
There was no showing in the defendants’ acts that they intended to compel Macaria to
marry Pedro. For one to be convicted of attempted coercion, the acts of the accused
must directly tend to the intended result of compelling the victim to do acts against his/her
will. They must be direct. They must be the beginning of the execution of the crime, with
a direct, rational, and necessary tendency to produce the intended result. This is not the
case here.
Ruling:
Appellants are found guilty of illegal detention.
Relevant Provisions:

DIGEST - People v. Crisostomo PDF

Uploaded by

Copyright:

Available Formats

DIGEST - People v. Crisostomo PDF

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

DIGEST - People v. Crisostomo PDF

Uploaded by

Copyright:

Available Formats

12. People v.

FOR COERCION TOPIC:

Notwithstanding the undisputed deprivation of Macaria’s liberty, the crime cannot be

You might also like