People vs.

Catantan

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 boarded the pump boat of the
Pilapils, leveled a revolver at Eugene, and ordered them to lie down. Then, Ursal boarded the
pumpboat and they hogtied Eugene. The accused left behind their pump boat with its
passenger’s 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 pump boat and ordered them to bring them to Mungaz, Cebu.
As Ursal was transferring to Juanito’s pump boat, he kicked the front part of the Pilapil’s boat.
The jolt threw Eugene off, Juan Jr untied his brother’s leg and they swam together clinging to
their boat. Another pumpboat passed, they were towed ashore and reported to the
authoritiesThe accused were caught when Juanito’s pump boat ran out of gas, but the revolver
was not found.

Issue:

Is the accused guilty of piracy as defined by PD 532 or grave coercionas defined by RPC 286

Held:

The accused is guilty of piracy as defined by PD 532

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

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.

In the present case the Supreme Court ruled that the case at bar falls squarely within the
purview of piracy. While it may be true that the Pilapil’s were compelled to go elsewhere other
than their place of destination, such compulsion was obviously part of seizing their boat. The
testimony of Eugene, one of the victims, shows that the appellant actually seized the vessel
through force and intimidation.

The Court said that to sustain the defense and convert the case of piracy to 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, the very act punished by PD
532.