G.R. No. 120350 ; October 13, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FREDDIE YAMBOT y DELOS SANTOS, FRANCIS VERSOZA, ARNILO GAVIOLA y CARBAJAL, MARCIANO SAYASA, and EDGARDO LINGAN, accused-appellants.

FACTS

The accused-appellants were charged with Kidnapping for Ransom for the abduction of Francisco J. Bernabe on February 7, 1994, in Valenzuela, Metro Manila. The prosecution established that the kidnapping was meticulously planned during meetings presided over by appellant Marciano Sayasa. The group was divided into two teams. The first team, which included state witness Renato Jamorawon, forcibly took Bernabe and his wife at gunpoint from their vehicle. The wife was later released with a ransom note demanding twenty million pesos (P20,000,000), while Bernabe was detained in Sapang Jaen, Nueva Ecija. The second team, including appellants Versoza and Lingan, acted as backup. Appellant Freddie Yambot, referred to as “Colonel,” was identified as a leader who received updates during the abduction.
The defense of appellants Gaviola, Sayasa, and Lingan consisted of denial and alibi. They claimed they were elsewhere during the incident—Gaviola and Lingan allegedly working on a farm in Nueva Ecija, and Sayasa claiming he was in Manila. The trial court found the testimonies of the prosecution witnesses, particularly the victim, his wife, and the state witness, to be credible and consistent, thereby establishing the conspiracy and participation of all appellants.

ISSUE

Whether the accused-appellants are guilty beyond reasonable doubt of the crime of Kidnapping for Ransom.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the collective testimonies of the prosecution witnesses, corroborated by physical evidence, to be credible and sufficient to establish guilt beyond reasonable doubt. The defense of alibi and denial was correctly rejected by the trial court. Alibi is inherently weak and cannot prevail over the positive identification of the accused by credible witnesses. For alibi to prosper, the accused must demonstrate not only that they were elsewhere when the crime occurred but that it was physically impossible for them to have been at the scene. Appellants failed to prove such physical impossibility. Their presence and participation in the planning and execution of the kidnapping were positively established. The crime of Kidnapping for Ransom, penalized under Article 267 of the Revised Penal Code, as amended by R.A. No. 7659 , was duly proven. All elements were present: the actual kidnapping and detention of Bernabe, the involvement of private individuals (not members of the military), and the demand for ransom. The Court affirmed the imposition of the death penalty on appellants Yambot and Versoza, finding no mitigating circumstances. For appellants Gaviola, Sayasa, and Lingan, the penalty was commuted to reclusion perpetua in line with prevailing jurisprudence, as their participation, while proven, was considered that of accomplices.