G.R. Nos. 140900 & 140911; August 15, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODERICK LICAYAN @ RUDY, ROBERTO LARA @ TUNGKOY/UNYOK, PEDRO MABANSAG @ PUTOL (At large), ALEX PLACIO (At large), JOJO SAJORGO (At large), ALLAN PLACIO (At large), NOEL DELOS REYES (At large), DODONG ADOLFO (At large), and BENJIE MABANSAG (At large), accused, RODERICK LICAYAN @ RUDY, ROBERTO LARA @ TUNGKOY/UNYOK, accused-appellants.

FACTS

Complainants Joseph Tomas Co, a restaurant owner, and Linda Manaysay, his cashier, were making their routine rounds of restaurant branches in the early hours of August 10, 1998. At their Sampaloc branch, three armed men approached Co. When Manaysay came out, the men, refusing to take money from the store, forced both complainants into the rear of Co’s Tamaraw FX vehicle. Two other men were already in the front. Co identified accused-appellant Roderick Licayan as one of the five abductors. Their hands were tied, eyes taped, and heads covered with caps. After a 45-minute ride, they were brought into a house with a room made of light materials and no ceiling. There, their eye covers were removed and their feet tied. Manaysay identified both accused-appellants in the house. Their personal belongings, including cash, a watch, jewelry, and wallet, were taken. Accused-appellant Roberto Lara was left to guard them. After Lara fell asleep, the complainants managed to escape, sought refuge in a nearby house, and contacted the Marikina police. A subsequent police raid on the safehouse in Daang Bakal, Parang, Marikina led to the arrest of Roberto Lara, who then pointed to Roderick Licayan’s location, leading to Licayan’s arrest. Both were identified by the complainants in a police line-up. Benjamin Co, Joseph’s brother, testified about receiving ransom demands of P10 million. The accused-appellants raised the defense of alibi. Licayan claimed he was at home having dinner during the incident and was arrested the next day while having drinks. Lara claimed he was at work in Antipolo on August 10 and was arrested on August 11 at his uncle’s house in Marikina while retrieving belongings.

ISSUE

The central issue is whether the accused-appellants, Roderick Licayan and Roberto Lara, are guilty beyond reasonable doubt of the crime of Kidnapping for Ransom under Article 267 of the Revised Penal Code, as amended.

RULING

The Supreme Court affirmed the judgment of the Regional Trial Court finding accused-appellants Roderick Licayan and Roberto Lara guilty of Kidnapping for Ransom. The defense of alibi was rejected as it could not prevail over the positive identification by the victims, who had sufficient opportunity to see and recognize their captors during the ordeal. The court found the testimonies of the complainants credible, consistent, and corroborated by the arrest and investigation. The elements of kidnapping for ransom were established: (1) the accused kidnapped or detained the complainants; (2) the kidnapping or detention was illegal; and (3) the kidnapping was for the purpose of extorting ransom. The demand for P10 million from Benjamin Co confirmed the ransom motive. The court upheld the penalty of death imposed by the trial court, as the crime was committed with the use of a firearm, a qualifying circumstance under the law. The accused-appellants were also ordered to indemnify the complainants. They were acquitted of the separate charge of Robbery, as the taking of personal properties was deemed absorbed in the crime of kidnapping for ransom.