PEOPLE

VS. CRISOSTOMO (GAYYA) ISSUE: Whether Crisostomo should be convicted of abduc>on through violence – NO,
1923 | Romualdez, J | AbducDon the proper crime is illegal detenDon.

RATIO:
PeDDoners: People of the PH
Respondents: Pedro Crisostomo
1. Both Gabriel and Crisostomo had the required age for consenDng to marriage, and
Summary: it appears that there is no legal impediment from contrac>ng it.
Crisostomo was accused of the crime of abduc>on through violence, as he allegedly
• The inten>on to marry may someDmes consDtute unchaste designs, which may
dragged the vic>m, Gabriel, into a rice field against her will. He contended that he vi>ate such an inten>on. This is evident in a case of abduc>on of a minor with
only did so as they have both agreed to elope and get married (although he later the laDer's consent, in which the offender knows that she cannot legally consent
admiDed that rejected his proposal). The Court, however, ruled that seduc>on to the marriage, and yet elopes with her. In an abduc>on of this nature
cannot be presumed as both par>es are of the required age and there is no legal seducDon is presumed by the law which may very well be covered by the
impediment for them to marry. More importantly, the essen>al element of inten>on to her married.
abduc>on, which is lewd design, was not conclusively proven.
2. The Court held that for the offense to cons>tute abduc>on, there must be the
Doctrine: existence of unchaste designs.
In the absence of the element of unchaste design or intent to abuse, the crime
• Under the old Spanish laws, abduc>on is taking away of a woman from her house
cannot be considered as abduc>on through violence, but merely illegal deten>on. or the place where she may be for the purpose of carrying her to another place
with intent to marry or to corrupt her.
FACTS: • The elements cons>tu>ng abduc>on through violence are: that it be commiDed
with unchaste designs —that is, with intent to abuse her. If such an inten>on
does not exist, the act will no longer cons>tute the crime of abduc>on, but a
1. Crisostomo, and 2 others were held guilty as principals, as well as 3 others as
crime against liberty, or that of illegal detenDon.
accomplices, of the consummated crime of abducDon through violence.
2. On their way home at 9am, Gabriel (vic>m) and her aunt, Acuna met Crisostomo
3. Even considering that it was proven that Crisostomo had the inten>on to marry
along with the other accused. Crisostomo dragged Gabriel against her will into a
Gabriel, such designs cannot be considered as unchaste.
rice field, while the others caught hold of Acuna to prevent her from helping her
niece. • It was not proven that Crisostomo kissed her many Dmes against her will, as
she was seasick and unconscious. It may be the case that the kissings were mere
3. Another woman, heard the her cries of Acuna, who then rushed to the scene and
accidental collisions of heads or faces. (hehe)
thereaCer aDacked the aggressors with a club.
4. As soon as Acuna was released, she went to the house of Gabriel and reported the • Also, it does not appear from the evidence that outside of those supposed
kissings, the accused or any of them ever commiDed any slight unchaste act.
incident to Gabriel’s brother, who also went aCer the aggressors. Upon seeing him,
they released Gabriel. • It was incumbent upon the prosecu>on to prove that all the offenders were
actuated by unchaste designs, but such unchaste designs were not proven. It
5. As a defense, Crisostomo explained that he and Gabriel agreed to elope/ run away
was not necessary to show that such designs were carried into effect, but it was
from her house so that they can be married (magtatanan)
required to establish the existence itself of the unchaste inten>on.
6. Gabriel denied such allega>on claiming that she was taken against her will.
7. Gabriel also alleged that at that >me, she was 30 years old so it must be presumed
3. It is undeniable, however, that Crisostomo deprived Gabriel of her liberty, even if he
that her decisions are more reflexive and cauDous compared to a young woman
did not place her in an closure. Illegal deten>on may consist not only in imprisoning
driven with the impulse of passion. Also, if it were true that they would elope, they
a person, but also in detaining her or depriving her liberty in any manner. Thus,
would not do it in broad daylight and with the presence of her aunt.
without the element of lewd designs, the crime is only illegal deten>on.
8. Crisostomo also admiDed that he deemed it advisable to abduct Gabriel, in view of
the fact that she firmly rejected his proposal.