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People v Catantan

Petitioners: People of the Philippines; Eugene Pilapil and Juan Pilapil Jr.

Respondents: Emiliano Catantan

Facts:

- Emilio Catantan and Jose Macven Ursal were convicted of violating PD 232 Anti-Piracy
and Highway Robbery Law. Only Catantan appealed.
- June 27 1993, The Pilapil brothers were fishing some 3km away from the shores of
Tabogon Cebu.
- Suddenly, another boat caught up to them. Catantan borded the pumpboat of the
Pilapils, leveled a revolver at Eugene, and ordered them to lie down
- Then, Ursal boarded the pumpboat and they hogetied Eugene. The accused left behind
their pumpboat with its passengers one of whom was also tied.
- While travelling to Daan Tabogon as compelled by the accused , the engine stalled twice
and the brothers were ordered to row the boat.
- As they passed by the shoreline of Nipa, They saw another boat operated by a certain
Juanito. The Pilapils told the accused that the engine was new.
- Catantan ordered the Pilapils to approach the boat cautioning them not to speak or
move
- On the pretext that they were buying fish, Catantan boarded the new pumpboat and
ordered them to bring them to Mungaz, Cebu.
- As Ursal was transferring to Juanitos pumpboat, he kicked the front part of the Pilapils
boat.
- The jolt threw Eugene off, Juan Jr untied his brothers leg and they swam together
clinging to their boat.
- Another pumpboat passed, they were towed ashore and reported to the authorities
- The accused were caught when Juanitos pumpboat ran out of gas, but the revolver was
not found.

Issue:

W/N the accused was guilty of piracy 1as defined by PD 532 or grave coercion2 as defined by
RPC 286.

Held:

1 P.D. 532 defines piracy as: any attack upon or seizure of any vessel, or the taking away of the
whole or part thereof or its cargo, equipment, or the personal belongings of its complement or
passengers, irrespective of the value thereof, by means of violence against or intimidation of
persons or force upon things, committed by any person, including a passenger or member of the
complement of said vessel, in Philippine waters, shall be considered as piracy. The offenders shall
be considered as pirates and punished as hereinafter provided

2 RPC Art. 286 defines graver coercion as: imposing upon any person who, without
authority o law, shall by means of violence threats or intimidation, prevent another from
doing something not prohibited by law, or compel him to do something against his will,
whether it be right or wrong.
Despite the accused argument that he and his companions did not attach or seize the fishing
boat, nor had any intention of permanently taking possession or depriving the complainants of
their boat, they are guilty of piracy. The act of compelling the Pilapils to take them elsewhere
other than their original place of destination was part of the act of seizing the boat.

The accused insists that they had no intention of depriving the Pilapils permanently of their
boat, proof of which they left behind the brothers with their boat, the truth is, the accused
abandoned the Pilapils only because the engine broke down and they needed another mean to
return to their lair.