- Petitioner
- People
- Respondent
- Bernardo Reyes
- Citation
- G.R. No. L-7712
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Paras, C.J.
- Decided
- March 23, 1956
Whether an information for coercion under Article 287 of the Revised Penal Code is sufficient without alleging violence as an element
Summary
This criminal case involved defendants who allegedly seized a passenger jeep belonging to another person through deceit and misrepresentation to answer for a debt. The Municipal Court and Court of First Instance dismissed the case because the information did not allege violence, which they believed was required for coercion under Article 287. The Supreme Court reversed, holding that the second paragraph of Article 287 covers 'other coercions or unjust vexations' that do not require violence as an element. The Court distinguished this from the first paragraph which specifically requires violence for taking a debtor's property. The case established that coercion can be committed through deceit and misrepresentation, not just violence, and that dismissal on insufficient information grounds does not bar re-prosecution.