G.R. No. 117624 December 4, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EFREN L. HERNANDEZ, DIONISIO S. JACOB @ Joe, CELSO MANSUER @ Boy Damo, JIMMY BOLANTE @ Bakulaw, (At Large), accused, ALFREDO T. TUMANENG @ Fred, JOSE L. LORENZO, @ Jomar, MARLON FAMODULAN, accused-appellants.

FACTS

On January 21, 1992, six-year-old Sharleen Tan was kidnapped from the Immaculate Concepcion Academy in San Juan, Metro Manila. Her nanny, Eva Sta. Cruz, testified that while she and Sharleen were about to board their family car driven by accused Jose Lorenzo, two unidentified men pushed her into the car. One man held her down, while the other took Sharleen. During the drive, Lorenzo asked the men, “Saan tayo?” to which one replied, “Sa dati.” The car proceeded to a house where Sharleen was taken inside. Eva was later released to relay the ransom demand. Sharleen’s father, Jacinto Tan, negotiated with the kidnappers, ultimately leaving P409,000 as ransom. Sharleen was released a week later at a hospital. An investigation led by the Central Intelligence Service (CIS) identified seven accused. Five—Efren Hernandez, Alfredo Tumaneng, Jose Lorenzo, Dionisio Jacob, and Marlon Famodulan—were apprehended and executed extrajudicial confessions detailing their roles. Celso Mansuer and Jimmy Bolante remained at large. During trial, Hernandez and Jacob escaped but were tried in absentia. The prosecution’s case relied heavily on the extrajudicial confessions and the testimonies of Eva Sta. Cruz and Jacinto Tan. The accused appellants denied the charges, claiming their confessions were coerced.

ISSUE

The primary issue is whether the extrajudicial confessions of the accused-appellants are admissible as evidence and sufficient to prove their guilt beyond reasonable doubt for the crime of Kidnapping for Ransom.

RULING

The Supreme Court affirmed the conviction. The extrajudicial confessions were deemed admissible as they were executed voluntarily with the assistance of counsel, Atty. Solomon Villanueva. The confessions were corroborated by each other and by the testimony of Eva Sta. Cruz, particularly regarding Lorenzo’s participation as the driver. The Court found that the collective details in the confessions established a conspiracy among the accused. The defense of denial and alibi by the appellants was rejected for being weak and unsupported by clear evidence. The arrest of Tumaneng was ruled valid as it fell under a warrantless arrest permissible under Rule 113, Section 5(b) of the Rules of Court, as the arresting officers had personal knowledge based on their surveillance that he was involved in the kidnapping. The Court upheld the trial court’s decision, finding all accused-appellants guilty beyond reasonable doubt of Kidnapping for Ransom.