G.R. No. L-59604 November 14, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff, vs. VICTORIO PIA y BAYHON, GAUDENCIO LAMANGAN y SARIA, VENANCIO PIA y BAYHON, DIOSDADO ANCIADO y AMORA, MARIO GARCIA y UMALI, and EDUARDO VINA y MONTEMAYOR, accused.

FACTS

The case involves the kidnapping and serious illegal detention of spouses Juanito Chua and Elma Diato Chua on December 28, 1977, in Imus, Cavite. Immediately after parking his car, Juanito Chua was accosted by two men; one poked a gun at his head while the other, later identified as accused-appellant Gaudencio Lamangan, held a knife to his neck. The couple was bound, taken to a hut, and held for ransom. The kidnappers initially demanded P100,000 but later agreed to P18,000. Elma Chua was released to secure the money, while Juanito remained detained until his rescue by Philippine Constabulary personnel on January 3, 1978.
An information was filed against Lamangan and several others. During trial, some co-accused escaped or remained at large. The trial proceeded against Lamangan, Diosdado Anciado, and Mario Garcia. The Court of First Instance of Cavite found them guilty. Lamangan, sentenced to death as a principal, appealed automatically. Anciado and Garcia, sentenced as accessories, were given prison terms. Lamangan contested his conviction, arguing his extrajudicial confession was inadmissible and that his guilt was not proven beyond reasonable doubt.

ISSUE

The core issue is whether the guilt of accused-appellant Gaudencio Lamangan for the crime of Kidnapping and Serious Illegal Detention has been established beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court found Lamangan’s guilt proven beyond reasonable doubt. His challenge to the admissibility of his extrajudicial confession was rejected. The confession was executed in the presence of counsel de oficio, and his claim of coercion was deemed baseless as he failed to complain promptly to the counsel or the investigating judge. More critically, even disregarding the confession, the testimonial evidence independently established his culpability.
The victim, Juanito Chua, positively identified Lamangan in court as the person who held a knife to his neck during the abduction and as one of his captors in the hut. This testimony was corroborated by his wife, Elma Chua, and PC Sergeant Rodolfo Habana. The Court held this direct and consistent identification sufficient to prove Lamangan’s participation as a principal in the crime. The offense is Kidnapping and Serious Illegal Detention under Article 267 of the Revised Penal Code, as amended. Since the kidnapping was committed for the purpose of extorting ransom, the prescribed penalty is death. However, considering the mitigating circumstances that the victim was rescued unharmed and no ransom was ultimately paid, the Court exercised its discretion to reduce the penalty to reclusion perpetua. The decision of the trial court was thus affirmed with this modification.