G.R. No. 118570 October 12, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENEDICTO RAMOS y BINUYA alias “Bennie”, accused-appellant.

FACTS

On July 13, 1994, around 6:30 AM, American pastor Malcolm Bradshaw witnessed accused-appellant Benedicto Ramos y Binuya struggling with Alicia Abanilla at an EDSA bus stop in Quezon City. Abanilla managed to enter Bradshaw’s car, but Ramos also forced his way in. Ramos, armed with a gun, ordered Bradshaw to drive on despite an attempt to stop for a traffic policeman. During the ride, Abanilla asked Ramos questions implying he was holding her hostage. Ramos directed Bradshaw to stop at Rajah Matanda Street, Project 4, Quezon City, where he forcibly pulled Abanilla out of the car. She whispered to Bradshaw that she might not survive and to notify her family. Bradshaw later found a receipt with Abanilla’s contact details.
Around 7:15 AM, Abanilla called her boss, Atty. Pastor del Rosario, urgently requesting P200,000 in cash for her release, instructing that it be delivered by a messenger (Inday) to Glori Supermart, Sikatuna Village. Del Rosario gathered the money and sent his driver, Serrano Padua, with Inday to deliver it.
Meanwhile, Ramos and Abanilla took a taxi driven by Antonio Pineda to Sikatuna Village. Pineda, for a fee, agreed to wait and later take them to Norzagaray, Bulacan. At the rendezvous, Pineda acted as intermediary to receive the ransom money from Inday after she verified Abanilla’s identity. Ramos then ordered Pineda to drive to Norzagaray but later changed the destination to Bocaue, Bulacan.
In Bocaue, they stopped at St. Paul Hospital compound. Pineda saw Ramos strangling Abanilla in the taxi. When Pineda protested, Ramos ordered him to drive to MacArthur Highway. Upon seeing a traffic aide, Gil Domanais, Pineda stopped and reported the strangling. Domanais approached and saw Abanilla crying, stating Ramos was armed and hurting her. Ramos then pulled out his gun, causing Domanais and Pineda to flee. Ramos took the driver’s seat and drove off. Abanilla jumped from the moving taxi but was dragged as her blouse got caught. Ramos stopped, and as Abanilla tried to rise, he shot her twice in the back of the head. Domanais fired at Ramos but missed. Ramos fled on foot but was apprehended later that day by Bocaue police in a grassy area. The police confiscated his .22 caliber revolver and recovered P138,630 of the ransom money. An autopsy confirmed Abanilla died from gunshot wounds to the head.
An Information was filed charging Ramos with the complex crime of kidnapping for ransom with murder. He pleaded not guilty, claiming Abanilla was his wedding godmother and he was merely seeking financial help for his pregnant wife, leading to an argument. The trial court found him guilty of two separate heinous crimes—kidnapping for ransom and murder—and sentenced him to death for each, plus indemnity.

ISSUE

The central issue for automatic review is the correctness of the trial court’s decision finding accused-appellant Benedicto Ramos y Binuya guilty of kidnapping for ransom and murder and imposing the death penalty for each crime.

RULING

The Supreme Court affirmed the trial court’s judgment with modifications. The Court held that the prosecution proved beyond reasonable doubt that Ramos committed the crimes of kidnapping for ransom and murder. The series of events from the initial abduction on EDSA, the extortion of ransom, to the eventual killing of Abanilla in Bocaue constituted two separate crimes, not a complex crime. Kidnapping for ransom was consummated when Ramos deprived Abanilla of her liberty for the purpose of extorting ransom, which was paid. The murder was a separate act committed after the kidnapping had ended, as Ramos killed Abanilla while fleeing, not as a necessary means to commit the kidnapping. Therefore, two separate penalties were warranted.
The penalty for kidnapping for ransom under Article 267 of the Revised Penal Code, as amended by R.A. No. 7659, is death. The penalty for murder under Article 248 is reclusion perpetua to death. Considering the aggravating circumstances of treachery (attack from behind while victim was defenseless) and evident premeditation (planned abduction and ransom demand), the Supreme Court imposed the supreme penalty of death for both crimes. The Court also affirmed the award of civil indemnity and actual damages for funeral expenses. The decision was subject to automatic review for the imposition of the death penalty.