G.R. No. 148518; April 15, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. NARCISO SALDAÑA (At Large), ELMER ESGUERRA (At Large), FERNANDO MORALES, and ARTURO MALIT, accused, FERNANDO MORALES and ARTURO MALIT, appellants.

FACTS

On November 9, 1994, in Bacolor, Pampanga, appellants Fernando Morales and Arturo Malit, together with co-accused Narciso Saldaña and Elmer Esguerra, abducted five victims, including Jefferson Tan, his siblings, and their driver, from their L-300 van. The victims were blindfolded, transported to Bataan, and detained. The kidnappers demanded a ransom of ₱2 million from the victims’ father, Feliciano Tan. Jefferson was later brought to a PLDT office to speak with his father, who negotiated the ransom down to ₱92,000. Following police advice, Feliciano did not allow Jefferson to deliver the money personally. The kidnappers subsequently called, agreed to the reduced amount, and instructed Feliciano on the delivery.
The ransom of ₱92,000 was successfully delivered to the kidnappers, leading to the victims’ release. Appellants Morales and Malit were later arrested and charged with kidnapping for ransom. During trial, they raised the defense of alibi, claiming they were elsewhere during the incident. The Regional Trial Court found all accused guilty and imposed the death penalty, prompting an automatic review before the Supreme Court.

ISSUE

Whether the guilt of appellants Fernando Morales and Arturo Malit for the crime of kidnapping for ransom was proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction but modified the penalty. The prosecution successfully established all elements of kidnapping for ransom under Article 267 of the Revised Penal Code, as amended by R.A. No. 7659. The credible and consistent testimonies of victim-witness Jefferson Tan provided a clear and positive identification of both appellants as active participants in the abduction, detention, and ransom collection. Jefferson’s testimony was corroborated by his father, Feliciano Tan, regarding the ransom negotiations and payment.
The Court found the defense of alibi untenable. Alibi is inherently weak and must be supported by clear and convincing evidence that the accused was at another place for the duration of the crime’s commission and that it was physically impossible for them to be at the crime scene. Appellants failed to meet this burden. Their alleged locations were not so distant as to preclude their presence at the kidnapping. Their positive identification by the victim, who had a clear view of them during the ordeal, rendered their alibi worthless. The trial court’s assessment of witness credibility is accorded great respect. Consequently, the Supreme Court upheld the factual findings and the conviction for kidnapping for ransom. However, owing to the passage of R.A. No. 9346 prohibiting the death penalty, the Court modified the sentence to reclusion perpetua without eligibility for parole.