G.R. No. 137182 EN BANC April 24, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ABDILA SILONGAN Y LINANDANG, et al., appellants.

FACTS

On March 16, 1996, businessman Alexander Saldaña, along with Americo Rejuso, Jr., Ervin Tormis, and Victor Cinco, traveled to Sultan Kudarat to meet appellant Macapagal Silongan regarding a purported gold transaction. After a series of deceptions, including a trip to Cotabato City, their vehicle was stopped near a highway at night. Approximately fifteen armed men appeared, and Saldaña’s group was forcibly taken, tied, and blindfolded. Saldaña identified several appellants, including Macapagal Silongan, Abdila Silongan, Akmad Awal, and Rolly Lamalan, as part of the armed group that carried out the abduction.
The victims were detained in various mountain and river hideouts in Maguindanao. The kidnappers, including appellants Jumbrah Manap, Sacaria Alon, and Ramon Pasawilan, demanded a ransom of twelve million pesos from Saldaña. He was forced to write letters to his family, and negotiations ensued. After over six months in captivity, during which he was guarded by the appellants, Saldaña was released on September 24, 1996, following a military operation. Only eight of the numerous accused were apprehended and brought to trial.

ISSUE

Whether the prosecution proved beyond reasonable doubt the guilt of the appellants for the crime of Kidnapping for Ransom with Serious Illegal Detention.

RULING

Yes. The Supreme Court affirmed the conviction but modified the penalty. The Court found the testimony of Alexander Saldaña, the principal victim, to be credible, consistent, and sufficient to establish the elements of the crime. He provided detailed and positive identification of the appellants, describing their specific roles in the abduction, detention, and ransom demands. His account was corroborated by the circumstances of his prolonged detention and the ransom notes. The defense of alibi and denial proffered by the appellants was inherently weak and could not prevail over Saldaña’s positive identification.
The crime committed is Kidnapping for Ransom under Article 267 of the Revised Penal Code, as amended by R.A. No. 7659. All elements were present: the appellants were private individuals who kidnapped and detained Saldaña, depriving him of liberty for over three days, for the purpose of extorting ransom. The prescribed penalty at the time was death. However, in line with the prevailing jurisprudence following the enactment of R.A. No. 9346, which prohibits the imposition of the death penalty, the Supreme Court modified the penalty to reclusion perpetua without eligibility for parole. The awards of civil indemnity and moral damages were affirmed, with an additional award of exemplary damages.