Valenton, Francis Angelo T.

Criminal Law 2

1S

People vs Catantan (G.R. No. 118075)

Facts: The plaintiff-appellee is the People of the Philippines. The accused-appellant is Emiliano
Catantan y Tayong. In the case at bar, in June 27, 1993, the Pilapil brothers were fishing in the
sea some 3 km. away from the shores of Tabogon, Cebu. Then, another boat caught up with
them. One of the person boarded the said another boat was the herein accused. The latter boarded
the Pilapils and leveled his gun to Eugene Pilapil. Catantan struck Eugene with his gun and
ordered both Pilapils to dapa. The accused then ordered Ursal to follow him on Pilapil
brothers boat, and hogtied Eugene and covered the latter with a tarpuline. The herein accused
then directed a certain Juan Jr. to ferry them to Daan Tobogon. As they were far out in the sea,
Eugene reminded that they were now off-course but Catantan told Eugene to keep quiet or he
would be killed. The boat engine then later or onked out and Juan Jr was directed to row the boat.
Later, Juan Jr. managed to fix the engine, but they went farther out into the open sea and the
engine stalled again. And the they row the boat again. The pirates saw another boat. The accused
boarded it on the pretext that they were buying fish. The accused then drew his revolver and
threaten to kill the driver of the other boat. The other persons with Catantan then hopped in the
new boat. As they Juan Jr. was about to hop in, he hard kicked the boat causing Catantan to
fall, which gives him time to rescue his brother, and they swim away. They were charged with
piracy under PD 532, and trial court found the accused guilty. On appeal, the accused argues that
in order for him to be liable for piracy under PD 532, it is necessary that there be an attack on or
seizure of a vessel. He contends that he and his companions did not attack nor seize any boat, as
the merely boarded and that the use of force or intimidation was used to merely compel the
offended parties to take them to some place.

Issue: Whether or not the accused is guilty of Piracy.

Held: The Supreme Court said that the it was included in the whereas clauses that it is
imperative that said lawless elements be discouraged from perpetrating such acts of depredations
by imposing heavy penalty on the offenders, with the end in view of eliminating all obstacles to
the economic, social, educational and community progress of the people. This means that the
law intends to punish persons who shall provide obstacles in the progress of people whom the
law intends to protect such as fishermen. Also, the Supreme Court said that the use or showing of
a revolver to intimidate the offended party is an act of seizing the boat of Pilapil brothers.