FACTS:

In September 1, 1997, a team from the Department of Environment and Natural Resources (DENR) conducted an intelligence gathering and forest protection operation against illegal logging on the island of Daram, Samar. The team, composed of DENR employees and escorted by police officers, encountered Mayor Benito Astorga during their investigation of boat construction sites.

According to the complaint, Mayor Astorga detained the team for several hours, verbally assaulted them, and had armed men surround them. Eventually, the team was released after having dinner with Mayor Astorga.

As a result, a criminal complaint was filed against Mayor Astorga and his men, leading to their arrest and subsequent trial. Ultimately, the Sandiganbayan found Mayor Astorga guilty of arbitrary detention and sentenced him to imprisonment.

In response, Mayor Astorga filed a petition for review, arguing that the prosecution failed to prove the elements of the crime. He also pointed out that the joint affidavit of desistance executed by the complainants attested to his innocence.

ISSUES:

1. Whether the team was detained by the petitioner.

2. Whether the Joint Affidavit of Desistance undermines the credibility of the witnesses.

3. Whether the trial court's weight given to the evidence was correct.

4. Whether the trial court's reliance on the testimony of SPO1 Capoquian, who is not one of the private complainants, was justified.

5. Whether the team was prevented from leaving or if they willingly stayed.

6. Whether the Sandiganbayan judge's clarificatory questions compromised his impartiality.

7. Whether the penalty imposed by the trial court is proper.

RULING:

1. The team was detained by the petitioner. The court held that in determining whether a person was detained, physical restraint is not necessary. If the acts and actuations of the accused can produce fear in the mind of the victim sufficient to paralyze the latter and compel him to limit his actions and movements according to the wishes of the accused, then the victim is considered detained against his will. In this case, the presence of armed men with weapons pointed at the team, and their refusal to allow the team to go home, create enough fear and compulsion to establish that the team was detained.

2. The Joint Affidavit of Desistance does not undermine the credibility of the witnesses. The court ruled that an affidavit of desistance is merely an additional ground to support the defenses of the accused, but not the sole consideration for acquittal. The court must consider other circumstances creating doubts as to the truth of the witnesses' testimonies. In this case, the Joint Affidavit of Desistance did not contain clear repudiation of the material points alleged in the information and proven at the trial. The affidavit only expressed the lack of interest of the complainants to pursue the case and was aimed at improving the relationship between the complainants and the local officials. Therefore, the court did not give weight to the Joint Affidavit of Desistance.

3. The trial court's factual findings are conclusive and binding upon appellate courts unless some facts or circumstances of weight and substance have been overlooked, misapprehended, or misinterpreted.

4. The fact that SPO1 Capoquian is not one of the private complainants is completely irrelevant as neither penal law nor the rules of evidence require damning testimony to be exclusively supplied by the private complainants in cases of Arbitrary Detention.

5. The testimony of SPO3 Cinco and SPO1 Capoquian, who categorically denied that they were simply "whiling away the time" between their dinner with Mayor Astorga and their departure the following morning, supports the finding that the team was prevented from leaving.

6. The Sandiganbayan judge's clarificatory questions do not compromise his impartiality as a trial court has the authority to propound clarificatory questions to witnesses in order to ferret out the truth.

7. The Court affirms the penalty imposed by the trial court in its entirety.

PRINCIPLES:

• Arbitrary Detention requires the elements of a public officer or employee detaining a person without legal grounds.

• Physical restraint is not necessary for detention; acts and actuations that produce fear and compel a person to limit his actions and movements are sufficient.

• An affidavit of desistance is not the sole consideration for acquittal; the court must consider other circumstances that doubt the testimonies of the witnesses.

• The trial court's factual findings are conclusive and binding upon appellate courts unless some facts or circumstances of weight and substance have been overlooked, misapprehended, or misinterpreted.

• Neither penal law nor the rules of evidence require damning testimony to be exclusively supplied by the private complainants in cases of Arbitrary Detention.

• The Sandiganbayan, as a trial court, can propound clarificatory questions to witnesses in order to ferret out the truth.

• The provisions of law punishing arbitrary or illegal detention committed by government officers must be earnestly enforced to reduce violations of personal freedom.

• The Court has the authority to modify the penalty imposed by the trial court if it is found to be erroneous or not in accordance with the law.

• The penalty imposed should be within the range prescribed by law and should be proportionate to the offense committed.

• Costs of the case may be imposed as determined by the Court.

• The concurrence of at least three (3) justices is required for a valid decision of the Court.