G.R. Nos. 113519-20 March 29, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO PANLILIO y FRANCISCO, defendant-appellant.

FACTS

Accused-appellant Danilo Panlilio was convicted by the Regional Trial Court of Valenzuela for Kidnapping under Article 267 of the Revised Penal Code and for Highway Robbery under P.D. 532. The charges stemmed from an incident on March 17, 1993, where Panlilio, using a knife concealed in a hat, accosted ten-year-old Leah Marie Jordan outside her school in Valenzuela. He forced her to board a jeepney, during which he forcibly took her pair of gold earrings. They proceeded to Navotas, where he dragged her to a vacant lot and threatened her before she was able to escape with the help of arriving policemen.
Panlilio denied the accusations, claiming he was merely warning the child about a garbage area in Navotas when policemen mistakenly arrested him. On appeal, he argued the trial court lacked jurisdiction over the highway robbery charge since the actual taking of the earrings allegedly occurred in Navotas, not Valenzuela. He also challenged the credibility of the victim’s testimony, questioning why no one noticed the abduction and the continuous poking of the knife during the journey.

ISSUE

The core issues were: (1) whether the RTC of Valenzuela had jurisdiction to try the highway robbery case; and (2) whether the prosecution proved Panlilio’s guilt for the crimes charged beyond reasonable doubt.

RULING

The Supreme Court affirmed the kidnapping conviction but dismissed the highway robbery case for lack of jurisdiction. On jurisdiction, the Court applied Section 15(b), Rule 110 of the Rules of Court, which states that for crimes committed on a public vehicle in the course of its trip, venue lies in any municipality where the vehicle passed, including the point of departure. The robbery, by the victim’s account, was committed inside the jeepney after it departed from Valenzuela. Therefore, the RTC of Valenzuela, as the place of departure, properly had jurisdiction. However, the trial court’s decision incorrectly stated the robbery occurred in Navotas, creating a fatal jurisdictional defect. Since jurisdiction is conferred by law and the allegations in the Information, the Court was constrained to dismiss the robbery case without prejudice to its refiling in the proper court.
On the merits of the kidnapping charge, the Court upheld the trial court’s findings. It ruled that the victim’s positive identification and credible testimony prevailed over the weak defense of denial and alibi. The explanation for the lack of outcry—the concealed knife and continuous threats to kill her—was deemed reasonable. The trial court’s assessment of witness credibility is accorded great respect. Thus, the conviction for kidnapping a minor female under Article 267(4) of the Revised Penal Code, penalized with reclusion perpetua, was affirmed.