### Facts:
The case involves Felix Caisip, Ignacio Rojales, and Federico Villadelrey (petitioners) being convicted of Grave Coercion by the Court of First Instance of Batangas and the conviction being affirmed by the Court of Appeals. The complainant, Gloria Cabalag, cultivated a parcel of land known as Lot 105-A of Hacienda Palico, which led to conflict with the Hacienda representatives and administration.
A sequence of legal battles ensued between Gloria Cabalag’s husband, Marcelino Guevarra, and the Hacienda over tenant rights, resulting in a court decision that rejected tenant status for Guevarra. Subsequently, an ejectment case filed against Guevarra resulted in a ruling for them to vacate the lot. However, issues arose regarding the execution of this decision as Guevarra appealed the decision, and there were disputes about the deadline for vacating the lot.
On June 17, 1959, while tending to the land within the grace period granted for vacating the property, Cabalag was forcibly removed by the petitioners, with Felix Caisip orchestrating the operation and the two policemen, Rojales and Villadelrey, physically dragging her from the lot. This event led to their conviction for grave coercion.
### Issues:
1. Whether the acts of Felix Caisip, Ignacio Rojales, and Federico Villadelrey were justified under Article 429 of the New Civil Code.
2. Whether the grace period given by the sheriff to vacate the lot was valid and lawful.
3. Whether the elements of grave coercion are present in the case.
4. Whether the defendants were rightfully convicted.
### Court’s Decision:
The Supreme Court affirmed the decision of the Court of Appeals, holding that the petitioners were rightly convicted of grave coercion. The Court found:
– Article 429 of the New Civil Code did not apply since the complainant was within her rights and did not unlawfully invade or usurp the lot.
– The grace period granted was implicitly ratified by the Hacienda’s representative present, making any actions taken by the defendants during this period unlawful.
– The act of weeding by Gloria Cabalag did not constitute a crime, and forcibly dragging her from the lot amounted to grave coercion.
– Felix Caisip, despite not physically attacking Cabalag, was found to be a co-conspirator and principal by induction due to orchestrating the coercive act.
### Doctrine:
This case reiterates the principle that individuals cannot take the law into their hands to exclude someone from a property, especially when due process and legal provisions grant the supposed infringer certain rights or grace periods.
### Class Notes:
– Grave Coercion: Forcibly compelling someone to do something against their will or preventing them from doing something not prohibited by law, without legal authority, constitutes grave coercion (Revised Penal Code, Art. 286).
– Legal Authority and Grace Periods: Actions taken against an individual must respect the legal authority and any grace periods granted by competent authorities.
– Co-conspirator and Principal by Induction: Orchestrating actions that lead to a crime can result in being held culpable as a co-conspirator or principal by induction, even without directly committing the physical act.
### Historical Background:
The case offers insight into the agrarian disputes in the Philippines, highlighting the complex legal battles over tenant rights and land cultivation. It also underscores the importance of legal authority in property disputes and the limitations on self-help measures, reflecting broader themes in Philippine legal and social history regarding land ownership and tenant rights.
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