G.R. No. 121901 January 28, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CLARITA BAHATAN y DULNUAN alias “JOVY BAHATAN,” accused-appellant.

FACTS

An Information dated June 2, 1994, charged Clarita Bahatan with Kidnapping and Serious Illegal Detention. It alleged that on March 18, 1994, inside Beth’s Restaurant in Bayombong, Nueva Vizcaya, she willfully, unlawfully, and feloniously took hostage Joyce Guerrero (alias Joyce Binaliw) by pointing a bladed weapon at her throat and detained her for less than three hours without legal justification. The accused pleaded not guilty. The prosecution presented witnesses Elizabeth Vendiola (the restaurant owner), the victim Joyce Guerero, and SPO4 Rolando Cara. Their testimonies established that at around 10:30 a.m., the accused suddenly poked a knife at Guerero’s neck inside the restaurant. Despite Vendiola’s plea, the accused continued, injuring Guerero’s finger and bumping her head against a wall. Vendiola locked the restaurant door and called the police. When police arrived, the accused refused to release the victim, threatened to kill her, and was allowed to leave with the victim to avoid harm. The accused, still holding the knife to Guerero’s throat, boarded a tricycle with her to Solano. After the victim refused the accused’s demand to “return to” her, they boarded another tricycle back to Bayombong. Police vehicles eventually blocked their path, and officers persuaded the accused to sheath the knife, then disarmed and arrested her. The victim was taken to the hospital for neck and hand injuries. The defense version, presented through the accused’s testimony, claimed she was talking to Guerero when she was suddenly attacked by Vendiola with a bolo. In self-defense, she grabbed a kitchen knife and held Guerero as a shield. When a policeman intervened and asked both to drop their weapons, she complied. Vendiola then told her to get her things and take Guerero with her. They voluntarily went to Solano to get Guerero’s belongings and were returning to Bayombong when police stopped and arrested her. The Regional Trial Court found the accused guilty beyond reasonable doubt and sentenced her to reclusion perpetua.

ISSUE

1. Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses and in disregarding the accused’s claim of self-defense.
2. Whether the trial court erred in finding the accused guilty beyond reasonable doubt of the crime of kidnapping and serious illegal detention.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the trial court’s Decision. On the first issue, the Court reiterated the settled rule that the assessment of witness credibility is best left to the trial court, which had the opportunity to observe their demeanor and manner of testifying. The trial court found the prosecution witnesses credible and their testimonies consistent. The accused’s claim of self-defense was properly rejected as it was inherently improbable; if true, the police would not have pursued, arrested her, or brought the victim for medical treatment. No improper motive was shown to impute false testimony upon the police witnesses. On the second issue, the Court held that all elements of Kidnapping and Serious Illegal Detention under Article 267 of the Revised Penal Code, as amended by R.A. No. 7659, were proven beyond reasonable doubt: (1) the offender is a private individual; (2) the victim was kidnapped or detained; (3) the act of detention or kidnapping was illegal; and (4) the victim was a minor, female, or a public officer. In this case, the accused, a private individual, illegally deprived the female victim of her liberty by force and intimidation, using a knife and threatening to kill her. The duration of detention (less than three days) is immaterial as the crime is qualified by the victim being a female and the threat to kill her. The penalty of reclusion perpetua was correctly imposed.