ARBITRARY DETENTION

Benito Astorga, petitioner,

Vs.
People of the Philippines, respondent.
412 SCRA 51

Facts: Benito Astorga is the mayor of Daram, Western Samar. A group of

people from Regional Special Operations Group from the DENR were sent to
conduct an investigation together with two policemen as their escort,
regarding possible illegal logging activities. Later on, the team found two boats
in the area. They found out that those boats belong to Mayor Astorga, when
Mayor Astorga found out about this, he went to the place and had a heated
altercation with the team. Mayor Astorga asked the DENR team to come with
him to his house to have dinner, and it was 2:00 o’clock in the morning when
they let them leave his house. Mayor Astorga was charged with Arbitrary
Detention for illegally detaining the DENR team, where he was found Guilty
by the trial Court.

Issue: Whether or not Mayor Astrorga was correctly charged with Arbitrary
Detention.

Held: No, Mayor Astorga was wrongfully charged of Arbitrary Detention. The
DENR team failed to prove that they were illegally detained by Astorga against
their will. When Astorga invited them to his home, had dinner and even drank
wine with them, converse with them and even laughed with them, this creates
reasonable doubt and clearly shows that fear did not exist in the minds of the
DENR team, and that they were not detained against their consent. Adding to
the fact that it was raining that day which prevented the DENR team to leave
the island. One of the requisites of Arbitrary Detention is when the offended
party is placed in confinement or there is restraint on his person or even if he
could move freely, as long as he could not escape for fear of being
apprehended again, which is not present in this case.