GR 113224; (September, 1996) (Digest)
G.R. No. 113224 September 11, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ABDUL HADI ALSHAIKA y SAHTA, accused-appellant.
FACTS
On October 29, 1993, Ghanem Hamad Al-Saheil was kidnapped at gunpoint outside Harrison Plaza in Manila. He was forced into a car where accused-appellant Abdul Hadi Alshaika was present. The victim was blindfolded, taken to a house in Quezon City, and detained. His personal items, including checks and a hotel safety deposit box key, were taken. The kidnappers, including Alshaika, demanded a ransom of One Million Pesos (P1,000,000.00) and threatened to kill him. After four days in captivity, he was released and dropped off to find a taxi. He immediately reported the crime.
The defense presented alibi, claiming Alshaika was at his home on Vito Cruz Street, Manila, during the incident. He also challenged the victim’s identification process, arguing it was impermissibly suggestive because he was the only suspect presented to the victim by police days after his arrest. The trial court convicted Alshaika of kidnapping for ransom under Article 267 of the Revised Penal Code and sentenced him to reclusion perpetua.
ISSUE
The core issue is whether the trial court erred in convicting the accused-appellant based on the victim’s identification and in rejecting the defense of alibi.
RULING
The Supreme Court affirmed the conviction. The victim’s positive identification of Alshaika was deemed credible and reliable. The Court ruled that while the police procedure of presenting a single suspect was not ideal, it did not automatically invalidate the identification. The victim had sufficient opportunity to observe his abductor during the prolonged captivity, which lasted several days, making his identification based on personal recollection rather than police suggestion. The defense of alibi was correctly rejected as it was not physically impossible for Alshaika to have been at the crime scene. Furthermore, alibi is inherently weak and cannot prevail over the positive identification by the victim. The prosecution successfully proved all elements of kidnapping for ransom, including the demand for P1,000,000.00. The penalty of reclusion perpetua was properly imposed, as the death penalty was constitutionally prohibited at the time.