GR 128045; (August, 2000) (Digest)
G.R. No. 128045 ; August 24, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMMEL DEANG, MELVIN ESPIRITU, and NICSON (or NIXON) CATLI, accused-appellant.
FACTS
On July 5, 1995, second-year high school student Arthur “Jay-Jay” Tanhueco was forcibly abducted by Melvin Espiritu and Rommel Deang from his school campus in Angeles City. The kidnappers then contacted Jay-Jay’s parents, Arturo and Shirley Tanhueco, demanding a ransom of three million pesos, later reduced to 1.48 million pesos. Shirley Tanhueco personally delivered the ransom on July 13, 1995, to Espiritu and Nicson Catli. She was blindfolded and left in a car, instructed to wait for her son, who never appeared.
During the investigation, the ransom calls were traced to a house where Deang was seen with Espiritu. Deang was apprehended, and a portion of the ransom money was recovered from him. His sworn statement implicated Espiritu, Catli, and another. On July 17, 1995, a boy’s body was found in Laurel, Batangas, bearing injuries from a mauling. The cadaver was later positively identified as Jay-Jay Tanhueco. Consequently, the information was amended to charge the accused with Kidnapping for Ransom with Homicide.
ISSUE
Whether the accused-appellants are guilty beyond reasonable doubt of the crime of Kidnapping for Ransom with Homicide.
RULING
Yes, the Supreme Court affirmed the conviction. The prosecution successfully established all elements of the crime. The fact of kidnapping was proven by eyewitness accounts of the forcible abduction. The demand and payment of ransom were established through the testimonies of the victim’s parents and the recovery of marked money. The corpus delicti for the homicide was proven by the recovery and identification of Jay-Jay’s body and the medical findings on the cause of death. The Court found the testimonies of the prosecution witnesses credible and consistent.
The defense of denial and alibi proffered by the appellants was rejected for being inherently weak and uncorroborated. The Court upheld the trial court’s findings on the existence of conspiracy, as the appellants’ collective actions—from the abduction, detention, and ransom negotiation to the collection of payment—demonstrated a common purpose. The killing of the victim, even after the ransom was paid, is absorbed in the special complex crime. The penalty of death was properly imposed, but in line with prevailing jurisprudence, is reduced to reclusion perpetua, without eligibility for parole, and the appellants were ordered to pay civil indemnity, moral damages, and the ransom amount.