Astorga vs.

People
GR No. 154130, August 20, 2004
Ynares-Santiago, J.

Facts:

During an intelligence operations for possible illegal logging activities in Daram Western
Samar, private offended parties as members of the Regional Special Operations Group
(RSOG) of the Department of Environment and Natural Resources together with some
members of the Philippine National Police Regional Intelligence had a heated argument
with herein petitioner Benito Astorga, Mayor of Daram who turned to be the owner of
two boats being constructed therein. Then upon call of the petitioner, ten armed men,
some wearing fatigues arrived for a backup whereupon the DENR Team was brought to
the petitioners house in which they had dinner. In view of the foregoing, the petitioner
was then charged with Arbitrary Detention and was convicted by the Sandiganbayan.
Petitioner filed a petition for review but to no avail. He then filed two motions for
reconsideration, the latter asserting that the crime charged against him was wanting in
evidence in view of the purpose of the detaining of said parties and of the ascertainment
of his criminal intent.

Issue:
Whether or not the acts of Astorga constituted grounds for Arbitrary Detention

Held:
No. A determinative factor of Arbitrary Detention is fear which appears to be
lacking in this case upon review of the evidence on the record. Apparently, Mayor
Astorga merely showed hospitality in accommodating the DENR Tem in his house as
testified by SPO1 Capoquian. Moreover, no actual restraint was shown wherein the
offended parties were free to leave the house but was unable to do so because of the
rain whence petitioner prevented them. With this lack of proof to ascertain accuseds
guilt beyond reasonable doubt, the court sustained the presumption of innocence that
an accused is entitled.

Therefore, the decision was revered and the petitioner was acquitted.