PEOPLE vs.

MERCADO
131 SCRA 501 (1984)

Kidnapping & serious illegal detention

Facts:
Federico or Alberto Mercado (may “or” talagasa case) surprised complainant Yvonne Baylon in the
morning of Sept. 2, 1979 and held her in a store for almost 5 hours, demanding that Yvonne produce her
younger sister Susan, which is the appellant’s common-law wife. Susan left home for an unknown place the day
before. Appellant contends that he should only be liable of grave coercion only since his purpose was to force
Yvonne to produce Susan.

ISSUES :
[WON he should be convicted of kidnapping and serious illegal detention and not grave
coercion

Held:
YES

RATIO:

The surrounding circumstances makeit clear that the main purpose of Annabel’s detention was to coerce
her intowithdrawing her previous charges against appellant Ablaza, thus obstructing the administration of
justice.”

The evidence in the case at bar shows that the accused held complainant (and restrained or deprived her
of her freedom) because he wanted her to produce her sister Susan.