People v. Marquez
REITERATIONFacts
The Antecedents: The complaining witness, Lamberto Quelato, testified that the defendants hung him by the feet to a beam in the warehouse of the defendant Marquez for two hours, accusing him of stealing a plow. This act resulted in an injury to his ankles that healed in fifteen days. Procedural History: The defendants were charged with a violation of Article 418 of the Penal Code. The testimony of the complaining witness was corroborated by the defendants' written declarations during the preliminary investigation, which were introduced as evidence in the Court of First Instance. Despite denying these declarations in the trial court, the judge found the evidence sufficient to sustain a conviction. The Petition: The defendants appealed their conviction.
Issue(s)
Whether the evidence is sufficient to sustain the conviction of the defendants for a violation of Article 418 of the Penal Code. Whether a fine can be imposed in addition to the penalty of arresto mayor under Article 418 of the Penal Code.
Ruling
The judgment below is modified by eliminating the provision in regard to the fine. In all other respects, it is affirmed with costs against the appellants. The case is to be remanded to the lower court for proper procedure.
Ratio Decidendi
On the sufficiency of evidence: The Court found that the testimony of the complaining witness, Lamberto Quelato, was sufficiently corroborated by the written declarations made by the defendants during the preliminary investigation. Although the defendants denied making these declarations in the Court of First Instance, the Supreme Court gave no credit to these denials. The Court held that the evidence presented was sufficient to sustain the conviction for the violation of Article 418 of the Penal Code. The corroboration provided by the defendants' own prior statements was crucial in overcoming their subsequent retraction. On the imposition of a fine with arresto mayor: The Court ruled that when the penalty of arresto mayor is imposed under Article 418 of the Penal Code, it is improper to also impose a fine. This ruling is based on the established jurisprudence of the Supreme Court. The Court cited its own previous decision in United States vs. Flemister to support this principle. Therefore, the portion of the judgment imposing a fine was ordered to be eliminated, as it was contrary to the proper application of the penalty prescribed by law. The penalty of arresto mayor already carries its own range of imprisonment, and the law does not permit the imposition of an additional fine in such cases.
Main Doctrine
When the penalty of arresto mayor is inflicted under Article 418 of the Penal Code, it is improper to impose a fine also.