PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
EMILIANO CATANTAN y TAYONG, accused-appellant.
G.R. No. 118075 September 5, 1997
FIRST DIVISION
BELLOSILLO, J.:
Facts:
It is an appeal made by the accused-appellant Emiliano Catantan y Tayong against the decision of
the Regional Trial Court of Cebu, contending that the trial court erred in convicting him of piracy as the
facts proved only constitutes grave coercion defined in Art. 286 of the Revised Penal Code and not piracy
under PD No. 532. Accused-appellant argues that in order that piracy may be committed it is essential
that there be an attack on or seizure of a vessel. He claims that he and his companion did not attack or
seize the fishing boat of the Pilapil brothers by using force or intimidation but merely boarded the boat,
and it was only when they were already on board that they used force to compel the Pilapils to take
them to some other place. The appellant also insists that he and Ursal had no intention of permanently
taking possession or depriving the complainants of their boat. As a matter of fact, when they saw
another pumpboat they ordered the brothers right away to approach that boat so they could leave the
Pilapils behind in their boat. Accordingly, the appellant claims, he simply committed grave coercion and
not piracy.
Issue:
Whether the accused-appellant committed grave coercion or Piracy under PD 532.
Held:
The Court affirmed the decision that the accused-appellant was guilty of the crime of Piracy under PD
No. 532. The Court ruled that under the definition of piracy in PD No. 532 as well as grave coercion as
penalized in Art. 286 of the Revised Penal Code, this case falls squarely within the purview of piracy.
While it may be true that Eugene and Juan Jr. were compelled to go elsewhere other than their place of
destination, such compulsion was obviously part of the act of seizing their boat. To sustain the defense
and convert this case of piracy into one of grave coercion would be to ignore the fact that a fishing vessel
cruising in Philippine waters was seized by the accused by means of violence against or intimidation of
persons.
