G.R. No. 137519 ; March 16, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. ANGELITO MARTINEZ and DEXTER TAGLE, appellants.

FACTS

Appellants Angelito Martinez and Dexter Tagle, along with several others, were charged with kidnapping for ransom and serious illegal detention for the abduction of Atty. Aquiles Lopez. The conspiracy was hatched on August 2, 1996. On August 4, 1996, the group, using a red Toyota Corolla and wearing police and military uniforms, intercepted Atty. Lopez’s vehicle along Quirino Avenue, Parañaque City. They identified themselves as narcotics agents, handcuffed and blindfolded the victim, and transported him to Martinez’s house in Valenzuela City. There, he was detained for four nights and three days. During his captivity, the kidnappers demanded a ransom of ten million pesos, later reduced to two million pesos, which was communicated to the victim’s daughter.
The victim’s family reported the kidnapping to the Presidential Anti-Crime Commission (PACC). Through surveillance, authorities located the victim’s vehicle and subsequently raided the Valenzuela safehouse on August 7, 1996, successfully rescuing Atty. Lopez. Martinez was arrested during the raid, while Tagle later surrendered. One co-accused, Rigor Aguilar, was discharged to become a state witness. The Regional Trial Court found appellants guilty beyond reasonable doubt and imposed the death penalty and moral damages.

ISSUE

Whether the guilt of appellants Angelito Martinez and Dexter Tagle for the crime of kidnapping for ransom under Article 267 of the Revised Penal Code, as amended, was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The prosecution successfully established all elements of kidnapping for ransom: (1) the accused deprived the victim of his liberty; (2) the deprivation was illegal; and (3) the act was committed for the purpose of extorting ransom. The testimonies of the victim, Atty. Lopez, who positively identified appellants as among his abductors, and the corroborating testimony of state witness Rigor Aguilar, provided a clear and consistent narrative of the conspiracy and the detention. The defense of denial and alibi proffered by the appellants was weak and could not prevail over the positive identification. The Court found the discharge of Aguilar as a state witness proper, as his testimony was absolutely necessary, corroborated, and he did not appear to be the most guilty.
Regarding the penalty, Article 267 mandates the imposition of the death penalty when the kidnapping is committed for the purpose of extorting ransom. The Court found no mitigating circumstances and several aggravating circumstances, including the use of motor vehicles, disguises, and the victim being a lawyer targeted due to his profession. Consequently, the death penalty was affirmed. However, pursuant to prevailing jurisprudence, the award of moral damages was reduced from One Million Pesos (₱1,000,000) to Seventy-Five Thousand Pesos (₱75,000).