G.R. No. 242696 , November 11, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ZALDY BERNARDO Y ESPIRITU, ET AL., ACCUSED-APPELLANTS.

FACTS

Accused-appellants Zaldy Bernardo, Monroy Flores, Danny Cortez, and Mila Andres Galamay, along with several others, were charged with Kidnapping for Ransom with Homicide and Murder. The prosecution established that on July 2, 1998, Dr. Eliezer Andres, Sr. went to meet individuals in Cainta, Rizal, regarding a gold bar transaction and was subsequently kidnapped. That same evening, Dr. Andres, Jr. received a ransom call from Galamay, a known family acquaintance. Major Igmedio Arcega, who had accompanied Dr. Andres, Sr., also went missing.
On July 4, 1998, during a police-monitored ransom payment in Manila, Dr. Andres, Jr. handed money to Bernardo. Following the exchange, police arrested Bernardo and several co-accused. A follow-up operation led to the arrest of Flores, Cortez, and others at a house in Caloocan City, where marked ransom money was found. Meanwhile, the body of Dr. Andres, Sr., bearing injuries and a gunshot wound, was discovered in Laguna on July 3, 1998. Major Arcega’s body was also later found.

ISSUE

Whether the guilt of the accused-appellants for the crimes of Kidnapping for Ransom with Homicide and Murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the convictions. The Court upheld the factual findings of the lower courts, emphasizing that the trial court’s assessment of witness credibility is accorded great weight. The prosecution successfully proved all elements of Kidnapping for Ransom with Homicide: the accused were private individuals; they kidnapped and detained Dr. Andres, Sr.; the deprivation of liberty was against his will; his death occurred during captivity; and ransom was extorted from his family. For Murder, the killing of Major Arcega was established with the qualifying circumstance of treachery.
The Court rejected the defenses of denial and alibi, which are inherently weak against positive identification. The collective actions of the accused, from the ransom demand by Galamay to the receipt of marked money by Bernardo and its recovery with Flores and Cortez, demonstrated conspiracy. Each conspirator is liable for all acts executed in furtherance of the common criminal design. The extrajudicial confession of a co-accused, while inadmissible against the others, was merely corroborative of the already strong evidence of conspiracy independently established by the prosecution. The penalties were modified to reclusion perpetua without parole for the kidnapping charge, in accordance with prevailing law.