FACTS:

The accused, Emiliano Catantan and Jose Macven Ursal alias "Bimbo," were charged with violation of PD No. 532, also known as the Anti-Piracy and Highway Robbery Law of 1974. They were accused of attacking and inflicting physical injuries on Eugene Pilapil and Juan Pilapil Jr., who were fishing in the seawaters of Tabogon, Cebu, while armed with a firearm and a bladed weapon. The accused seized the fishing boat of the Pilapil brothers and left them tied up in another boat.

The Regional Trial Court of Cebu found both accused guilty and sentenced them to reclusion perpetua. Only Emiliano Catantan appealed the decision. He argued that the trial court erred in convicting him of piracy, as the facts proved only constitute grave coercion.

The evidence for the prosecution showed that the accused boarded the Pilapil brothers' boat, assaulted Eugene, and forced both of them to take them to another boat. During the ordeal, the engine of the boat failed multiple times, but Eugene was only allowed to assist in fixing it after being threatened with harm. Eventually, another boat was approached, and the accused forced the operator to take them to another town. However, as they were transferring to the new boat, the Pilapils' boat was damaged, and Eugene ended up in the water. He and Juan Jr. were able to swim to safety with the help of another passing boat.

The issue in the appeal was whether the accused committed piracy or only grave coercion.

ISSUES:

1. Whether the actions of Emiliano Catantan and Jose Macven Ursal alias "Bimbo" constituted piracy under PD No. 532 or merely grave coercion under Art. 286 of the Revised Penal Code.

RULING:

1. The Supreme Court ruled that the actions of Emiliano Catantan and Jose Macven Ursal constituted piracy under PD No. 532. The Court emphasized that the act of seizing the fishing boat through force and intimidation, as described by the witness testimony, falls squarely under the definition of piracy as provided in Section 2, par. (d) of PD No. 532.

PRINCIPLES:

1. Piracy Under PD No. 532: Piracy is defined as any attack upon or seizure of any vessel in Philippine waters, involving violence or intimidation. The law is intended to discourage and prevent piracy by imposing heavy penalties on offenders to ensure the economic, social, educational, and community progress of the people.

2. Grave Coercion Under Art. 286 of the Revised Penal Code: Grave coercion involves someone using violence to compel another person to do something against their will without authority of law. However, in this case, the actions taken by the accused exceeded the mere act of coercion and amounted to piracy.

3. Jurisprudence on Evidence: The unavailability of the weapon (revolver) used in committing the crime does not exculpate the accused from responsibility, provided there is sufficient credible testimony establishing the use of force and intimidation during the commission of the crime.