GR 171655; (July, 2009) (Digest)
G.R. No. 171655 ; July 22, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. PABLO L. ESTACIO, JR. and MARITESS ANG, Appellants.
FACTS
Appellants Pablo Estacio, Jr. and Maritess Ang were charged with Kidnapping with Murder. The prosecution evidence, primarily from discharged co-accused Hildo Sumipo, established that on October 10, 1995, appellants and Sumipo met the victim, Charlie Chua, at a Quezon City bar. Inside Chua’s car, Estacio pulled a gun, subdued Chua, and with Ang’s assistance, bound and gagged him. They then drove to a secluded area in Bulacan where Estacio and Ang took Chua out. Estacio later returned with bloodied hands. During their escape, appellants discussed the killing and later made ransom calls to Chua’s mother, despite knowing he was dead. Chua’s remains were later recovered with Estacio’s assistance.
The Regional Trial Court convicted both appellants. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua. Appellants appealed, arguing the trial court erred in giving credence to Sumipo’s testimony and in finding conspiracy.
ISSUE
Whether the Court of Appeals erred in affirming appellants’ conviction for the complex crime of Kidnapping with Murder based on the evidence presented.
RULING
The Supreme Court denied the appeal and affirmed the convictions. The Court found the testimony of state witness Hildo Sumipo to be credible, consistent, and corroborated by other evidence, including Estacio’s own extrajudicial confession and his subsequent act of leading authorities to the victim’s remains. The elements of kidnapping and murder were sufficiently proven: the victim was forcibly taken and detained, and was killed by repeated stabbing. The Court upheld the finding of conspiracy, as the acts of Estacio and Ang—from the initial abduction, the detention during the car ride, their joint participation at the crime scene, to the subsequent ransom demands—demonstrated a united purpose and common design to commit the crime. The complex crime of Kidnapping with Murder is properly appreciated under Article 267 of the Revised Penal Code, as the killing was committed as a consequence of the kidnapping. The penalty imposed by the Court of Appeals, reclusion perpetua without eligibility for parole pursuant to Republic Act No. 9346, was affirmed.