GR 129306; (March, 2003) (Digest)
G.R. No. 129306 ; March 14, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. JAMES PATANO Y MARCAIDA, RAMIL MADRIAGA Y LAGONOY AND ROSENDO MADRIAGA Y BANAAG, appellants.
FACTS
The appellants, James Patano, Ramil Madriaga, and Rosendo Madriaga, were charged with Kidnapping for Ransom. The prosecution alleged that on March 25, 1996, they kidnapped Vicente Uy in Mandaluyong City, detained him in Antipolo, Rizal, and demanded a P10 million ransom. Uy testified that his car was bumped by a Pajero, after which he was forced inside, blindfolded, and transported to a location where ransom was negotiated. He was rescued on March 27, 1996. The defense presented alibis and denials. Patano claimed he was at a video shop and later at a friend’s house. Ramil Madriaga asserted he was merely a concerned informant who contacted the victim’s family after receiving a beeper message from his cousin Rosendo about Uy being in police custody. Rosendo Madriaga claimed he was at the resort to collect a debt from a certain Richard Dimal.
ISSUE
Whether the guilt of the appellants for the crime of Kidnapping for Ransom was proven beyond reasonable doubt.
RULING
The Supreme Court ACQUITTED appellants James Patano and Rosendo Madriaga but AFFIRMED the conviction of appellant Ramil Madriaga for Kidnapping for Ransom, modifying the penalty to reclusion perpetua. For Patano, the Court found his alibi credible and corroborated, creating reasonable doubt. The prosecution failed to present any witness who could positively identify him as a participant in the kidnapping. For Rosendo Madriaga, the evidence was insufficient to prove conspiracy. His mere presence at the resort cottage where Uy was found, without proof of any overt act to facilitate the kidnapping or demand ransom, did not establish criminal liability. His defense of being there to collect a debt remained unrebutted.
However, for Ramil Madriaga, his conviction stands based on his own judicial admissions and the totality of circumstantial evidence. He admitted contacting the victim’s family with false information that Uy was with the Antipolo police, knowing this was untrue, and leading them to the resort. His flight upon arrival at the resort and his subsequent plea to the victim’s daughter to exclude his cousin from the case are indications of guilt and consciousness of conspiracy with the kidnappers. These acts, performed to secure the ransom payment, constituted indispensable cooperation in the crime’s execution. The demand for ransom was proven through the testimony of the victim’s daughter regarding the kidnappers’ calls. The Court ruled that conspiracy was established for Ramil Madriaga, making him equally liable as a principal.