G.R. No. 181822 ; April 13, 2011
People of the Philippines, Plaintiff-Appellee, vs. Joel Baluya y Notarte, Accused-Appellant.

FACTS

An Information dated September 4, 2003, charged appellant Joel Baluya with kidnapping and serious illegal detention. It was alleged that on or about August 31, 2003, in Manila, appellant, a private individual, willfully, unlawfully, and feloniously kidnapped, took, detained, and carried away Glodil Castillon, a nine-year-old minor, by poking a knife at his back, twisting his hands, and forcibly bringing him to Novaliches, Quezon City, thereby detaining and depriving him of his liberty against his will.
The prosecution’s version established that around 10:30 a.m. on August 31, 2003, the victim, Glodil Castillon, was playing in front of his house in Sampaloc, Manila. Appellant called him, seized him by twisting his right arm, pointed a knife at him, and threatened that if his wife Marissa did not appear, Glodil’s mother would not see him again. Appellant and Glodil boarded a jeepney to Blumentritt, where appellant called Glodil’s mother, Gloria, demanding to see his wife. After a brief phone call with his mother, they proceeded to Novaliches. Appellant fetched his three minor children from a barbershop and left all the children at a playground within a church premises, checking on them periodically. At 3:30 p.m., appellant called Gloria again, shouting and threatening that she would not see her son if his wife was not produced. Police arranged a plan to arrest appellant when he went to meet his wife at the Novaliches market. Meanwhile, around 4:00 p.m., Glodil seized an opportunity to escape, walking for about four hours to return home by reading jeepney signboards.
The defense interposed denial, alleging that on August 31, 2003, appellant went to Gloria’s house to inquire about his wife. After talking for an hour, Glodil asked to accompany him to Novaliches, as he had done several times before, and Gloria gave permission. They proceeded to appellant’s house, had lunch, and appellant later took his children and Glodil to a playground. When appellant returned around 4:30 p.m., Glodil was gone; his children said Glodil was fetched by an aunt named Rosaly. Around 6:00 p.m., police arrived with Gloria and appellant’s wife, and he was arrested. Appellant claimed the accusation was a scheme by his wife and her aunt to take his children, and that Gloria was prejudiced against him because he is a “Waray.”
The Regional Trial Court found the prosecution’s version credible, convicted appellant of kidnapping and serious illegal detention, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction with modification, ordering appellant to pay moral and nominal damages.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s finding that appellant is guilty beyond reasonable doubt of the crime of kidnapping and serious illegal detention.

RULING

The Supreme Court affirmed the conviction. The prosecution adequately proved all elements of kidnapping and serious illegal detention under Article 267 of the Revised Penal Code: (1) the offender is a private individual; (2) he kidnaps or detains another or deprives him of liberty; (3) the act is illegal; and (4) the victim is a minor.
The Court found the prosecution’s evidence, particularly the credible testimony of the minor victim, sufficient to establish that appellant forcibly took, detained, and deprived Glodil of his liberty. The act of twisting the victim’s arm, poking a knife, making threats, and transporting him to a different city against his will constituted deprivation of liberty. The victim’s escape did not negate the crime, as the essence of kidnapping is the actual deprivation of liberty coupled with the intent to deprive. The defense of denial could not prevail over the positive identification and clear testimony of the victim. The minority of the victim was sufficiently established by the Information and testimony. The penalty of reclusion perpetua and the awarded damages were upheld.