G.R. No. 138456; October 23, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ROLANDO DEDUYO Y PIRYO alias “BATMAN” AND ISAGANI MAÑAGO (ACQUITTED), accused. ROLANDO DEDUYO Y PIRYO alias “BATMAN,” appellant.

FACTS

On January 30, 1994, appellant Rolando Deduyo, a former lessee known to the victim, approached 16-year-old Johnny Mauricio in Antipolo, Rizal. Deduyo deceitfully asked Johnny to accompany him to the airport to retrieve baggage, claiming he had already secured permission from Johnny’s mother. Trusting the appellant, Johnny agreed. They proceeded to a house in Pasig City where Deduyo’s cohorts, Isagani Mañago and a certain Bayani, were present. Johnny was detained overnight; Bayani brandished a knife and issued death threats, stating whoever entered would not leave alive. The following day, Deduyo gave Johnny fare money and sent him home.
Unbeknownst to Johnny, a ransom letter demanding P100,000 for his safe release was delivered to his mother, Salvacion Mauricio, on the afternoon of his abduction. The letter, signed by a group claiming to be the NPA, threatened to kill the family if the police were involved. Salvacion, though frightened, secretly alerted the authorities. Appellant was later identified as the kidnapper. After a trial in absentia due to his escape from jail, the Regional Trial Court convicted Deduyo of kidnapping for ransom and sentenced him to reclusion perpetua, while acquitting Mañago for lack of evidence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of appellant Rolando Deduyo for the crime of kidnapping for ransom.

RULING

The Supreme Court affirmed the conviction but modified the penalty to death. The legal logic centered on the elements of kidnapping for ransom under Article 267 of the Revised Penal Code, as amended. The Court found all elements present: (1) the victim was a minor; (2) he was deprived of his liberty, as his movement was restrained through deceit and intimidation from Bayani’s knife and threats; (3) the deprivation lasted for more than three days (from January 30 to 31, 1994); and (4) it was committed for the purpose of extorting ransom, as proven by the ransom note delivered to the victim’s mother. The appellant’s deceit in luring the victim and his direct involvement in the kidnapping scheme established his guilt as a principal.
The defense of frame-up was rejected for being unsubstantiated. The victim’s credible and consistent testimony, corroborated by the ransom note and his mother’s account, established guilt beyond reasonable doubt. The Court ruled that the qualifying circumstance of kidnapping a minor for ransom was present, warranting the supreme penalty under Republic Act No. 7659. The award of moral damages was deleted for lack of proof of psychological suffering. The decision was affirmed with the modification of the penalty to death, subject to executive clemency review.