Anti-Piracy and Anti-Highway Robbery

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PEOPLE OF THE PHILIPPINES v.

EMLIANO CATANTAN

G.R. No. 118075, 5 September, 1997, FIRST DIVISION, (Bellosillo, J.)

DOCTRINE OF THE CASE

While it may be true that the victims were compelled to go elsewhere other

than their place of destination, such compulsion was obviously part of the act of

seizing the boat.

FACTS

The Pilapil brothers were fishing in the shore of Tabogon Cebu. Respondent

Catantan and Ursal approached the brothers through their pumpboat and ordered latter

to lie down. While travelling, the boat stalled twice. Upon seeing another boat

approaching them, the respondent boarded the same and left the brothers. When the

second boat ran out of gas, the respondents were caught.

ISSUE

WON respondents are guilty of violating PD 532 or Grave Coercion under Article

286.

RULING

Respondent it guilty of violating PD No. 532. The act of compelling the Pilapil

brothers to take them elsewhere is considered as seizing. The Court rejects the

contention of the respondents that they had no intention of taking the boat from the

Pilapil brothers. The only reason why they left the boat is because it was broken.
Nonetheless, the offense was already consummated when they compelled the Pilapil

Brothers to take them to their desired place.


RAMON AMPARO Y IBANEZ v. PEOPLE OF THE PHILIPPINES

G.R. No. 204990, 22 February, 2017, SECOND DIVISION, (Leonen, J.)

DOCTRINE OF THE CASE

It is highway robbery only when it can be proven that the malefactors

primarily organized themselves for the purpose of committing that crime.

FACTS

Petitioners along with his three companions boarded on a jeep. One of them

approached Ignacio, the victim and pointed a knife on his body, and ordered the latter to

surrender his necklace and cellphone. Upon hearing a gunshot coming from a police

officer, they dropped their knives. After that they were arrested. The trial court convicted

them of committing robbery in a band pursuant to Article 294.

ISSUE

WON petitioners committed robbery in a band?

RULING

YES. PD 532 punishes as highway robbery or brigandage only acts of robbery

perpetrated by outlaws indiscriminately against any person on Philippine Highways. The

prosecution was able to prove that petitioners committed robbery in a band. Petitioners

cannot be punished under PD 532, since there are no evident grounds to convict them

of the crime. Their act is only considered a particular robbery which is considered only

as robbery in a band. PD 532 punishes as highway robbery

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