G.R. No. 186472 ; July 5, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. ANTONIO SIONGCO y DELA CRUZ, ERIBERTO ENRIQUEZ y GEMSON, GEORGE HAYCO y CULLERA, and ALLAN BONSOL y PAZ, Accused, ANTONIO SIONGCO y DELA CRUZ and ALLAN BONSOL y PAZ, Appellants.

FACTS

Between 6:00 and 7:00 p.m. on December 27, 1998, 11-year-old Nikko Satimbre was induced by accused Antonio Siongco, a former security guard at his mother’s workplace, to board a bus bound for Pilar, Bataan. Siongco was accompanied by his friends Marion Boton and Eriberto Enriquez, and Nikko was told they would get a “Gameboy” Siongco promised. After a stop in Pilar, they proceeded to Mariveles, Bataan, met accused George Hayco, and then brought Nikko to Dinalupihan, Bataan, where he was kept overnight. His mother, Elvira Satimbre, reported him missing after an unsuccessful search.
On December 28, 1998, Enriquez and Siongco took Nikko to Bicutan, Taguig, Metro Manila. The following day, December 29, Elvira received a phone call from Siongco, who demanded a ransom of ₱400,000.00 (later reduced to ₱300,000.00) for Nikko’s release. Elvira spoke briefly with her son before Siongco grabbed the phone, threatened to kill Nikko if the ransom was not delivered, and set a meeting for December 30 at Genesis Bus Station in Pasay City. Elvira reported the kidnapping to the police.
On December 30, Enriquez and Siongco moved Nikko to Pateros, staying at the house of Heracleo San Jose, a relative of Enriquez. They continued calling Elvira with threats and changing ransom delivery instructions. On December 31, after Elvira sought assistance from the Philippine Anti-Organized Crime Task Force (PAOCTF), a police team accompanied her to the bus station. Enriquez approached Elvira, took a brown envelope from her, and was arrested. Siongco, who had fled in a taxicab, was later arrested at Heracleo’s house in Pateros, where Nikko was rescued. Follow-up operations led to the arrests of accused Allan Bonsol, George Hayco, and Marion Boton.
An Information was filed on January 4, 1999, charging all accused with Kidnapping and Serious Illegal Detention under Article 267 of the Revised Penal Code. The Regional Trial Court (RTC) convicted Siongco, Bonsol, Enriquez, and Hayco, sentencing them to death, and acquitted Boton on reasonable doubt. The Court of Appeals (CA) affirmed the conviction but modified the penalty to reclusion perpetua and increased the damages. Only appellants Siongco and Bonsol perfected their appeal to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of appellants Antonio Siongco and Allan Bonsol for the crime of Kidnapping and Serious Illegal Detention.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with modification.
The Court upheld the findings of both the RTC and CA that all elements of Kidnapping and Serious Illegal Detention under Article 267 of the Revised Penal Code were proven beyond reasonable doubt: (1) the victim was a minor; (2) he was deprived of his liberty; (3) the deprivation was illegal; and (4) the kidnapping was for the purpose of extorting ransom. The testimonies of the victim, Nikko, and his mother, Elvira, were credible and consistent, detailing the abduction, detention, and ransom demands. The defense of denial and alibi raised by the appellants was weak and could not prevail over the positive identification and evidence of conspiracy.
The Court found that conspiracy was evident from the series of actions taken by the appellants and their cohorts in transporting, detaining, and making ransom demands for the victim. The penalty was properly modified to reclusion perpetua, without eligibility for parole, in accordance with Republic Act No. 9346 , which prohibits the death penalty. The awards of damages were also affirmed: ₱100,000.00 as moral damages and ₱100,000.00 as exemplary damages, to be paid jointly and solidarily by the appellants to the victim, Nikko Satimbre.