G.R. No. 120409 , October 23, 2003
People of the Philippines, Appellee, vs. Williamson Pickrell and Augusto Nolasco, Appellants.

FACTS

Appellants Williamson Pickrell and Augusto Nolasco were charged with kidnapping for ransom and physical injuries. The victim, 16-year-old Far East Raymond Ausmolo, was a close family friend of Pickrell. On September 5, 1991, Pickrell persuaded Ausmolo to accompany him to Nolasco’s office in Parañaque under a pretext. Once there, Nolasco suddenly tied up Ausmolo, citing a grudge against the victim’s father. Pickrell then instructed Nolasco to call the victim’s mother to demand a P100,000 ransom.
When the ransom was not produced, the appellants severely beat Ausmolo, placed him in a box, and transported him. Believing him dead, they dumped him in a trash can. He was found alive by barangay officials and rushed to the hospital. The prosecution presented the testimonies of the victim and his mother, alongside medical evidence and the ransom letter.

ISSUE

The core issue is whether the appellants are guilty beyond reasonable doubt of the complex crime of kidnapping for ransom with physical injuries, or if the acts constitute separate offenses.

RULING

The Supreme Court affirmed the conviction but modified the trial court’s ruling. The Court held that the appellants committed two distinct crimes: Kidnapping for Ransom under Article 267 of the Revised Penal Code, and Frustrated Homicide. The act of kidnapping was consummated the moment Ausmolo was deprived of his liberty and ransom was demanded. The subsequent brutal beating, done after the ransom demand failed, constituted a separate felonious act with the intent to kill, performed through acts of execution that would have resulted in death were it not for timely medical intervention independent of the appellants’ will. This qualifies as Frustrated Homicide under Article 249 in relation to Article 6 of the RPC.
The Court found the victim’s positive identification and credible narration of events, corroborated by other evidence, sufficient to establish guilt beyond reasonable doubt. Conspiracy was evident from their concerted actions to detain the victim, demand ransom, and later inflict fatal injuries. The penalty for Kidnapping for Ransom is reclusion perpetua to death; with no aggravating circumstances, reclusion perpetua was properly imposed. For Frustrated Homicide, an indeterminate penalty was applied. The awards for damages were also affirmed.