G.R. No. 178039; January 19, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ERNESTO UYBOCO y RAMOS, Defendant-Appellant

FACTS

The accused-appellant, Ernesto Uyboco y Ramos, along with the now deceased Colonel Wilfredo Macias and several John Does, was charged with three counts of Kidnapping for Ransom under three separate Informations (Criminal Case Nos. 93-130980, 93-132606, and 93-132607). The victims were the minor siblings Jeson Kevin Dichaves (5 years old) and Jeson Kirby Dichaves (2 years old), and their helper, Nimfa Celiz. The kidnapping occurred on the morning of December 20, 1993, in Manila. The accused, conspiring together, kidnapped and detained the victims to extort a ransom. A total ransom of ₱1,500,000 (composed of ₱1,320,000 in cash, assorted jewelry worth ₱175,000, and a Colt .45 caliber pistol) was paid for their release. The accused pleaded not guilty. The prosecution’s evidence established that the victims were forcibly taken while in their family car. Nimfa Celiz, the helper, managed to make secret calls to inform her employer of their location in Merville Subdivision, Parañaque. The father of the children, Jepson Dichaves, negotiated with the kidnappers, whose voice he recognized as that of the appellant due to prior business dealings. The ransom was delivered by Jepson at the Magallanes Commercial Center on December 22, 1993, following the appellant’s instructions. Police officers conducting surveillance positively identified the appellant as the person who retrieved the ransom bag from Jepson’s car trunk. The victims were subsequently released at a Shell Gasoline Station. The Regional Trial Court convicted the appellant, and the Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for three counts of Kidnapping for Ransom.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals. The Court found no reason to overturn the factual findings and conclusions of the lower courts. The prosecution successfully proved the appellant’s guilt beyond reasonable doubt. The elements of Kidnapping for Ransom were all present: (1) the accused kidnapped or detained another person, or in any manner deprived them of their liberty; (2) the act of kidnapping or detention was illegal; and (3) the kidnapping or detention was for the purpose of extorting ransom. The positive identification of the appellant by prosecution witnesses, including the victim Nimfa Celiz and the father Jepson Dichaves (who recognized the appellant’s voice), coupled with the testimonies and photographic evidence from the police officers who witnessed the ransom pay-off, constituted strong and credible evidence of the appellant’s participation in the conspiracy to commit the crime. The defense of denial and alibi proffered by the appellant was weak and could not prevail over the positive identification. The penalty imposed by the lower courts was in accordance with law. The death of co-accused Wilfredo Macias pending appeal extinguished his criminal liability.