GR 205442; (December, 2013) (Digest)
G.R. No. 205442 ; December 11, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JONATHAN CON-UI and RAMIL MACA, Accused-Appellants.
FACTS
Accused-appellants Jonathan Con-ui and Ramil Maca, along with others, were charged with the kidnapping and serious illegal detention of Alejandro Paquillo and three minor girls on October 14, 2001. The prosecution evidence established that Con-ui had been visiting Alejandro’s house to offer property for sale. On the night of the incident, while Con-ui was talking with Alejandro, armed men entered, hogtied Alejandro and the girls, and took money from a drawer. The victims were forcibly taken using Alejandro’s jeepney. Alejandro was later ordered to secure a P300,000 ransom. The victims were eventually released after the kidnappers learned of military operations. Con-ui claimed he was also a victim who was hogtied and later escaped, while Maca interposed alibi, claiming he was at a construction site and later working on a farm during the incident.
ISSUE
Whether the Court of Appeals correctly upheld the conviction of accused-appellants for the crime of Kidnapping for Ransom.
RULING
Yes, the Supreme Court affirmed the conviction. The legal logic centers on the essential elements of Kidnapping for Ransom under Article 267 of the Revised Penal Code: (a) the accused is a private person; (b) he kidnaps or detains another; (c) the deprivation of liberty is illegal; and (d) it is done for ransom. The Court found all elements proven beyond reasonable doubt. The credible testimonies of the victims, particularly Alejandro, detailed how appellants actively participated in the abduction and detention. The act of ordering Alejandro to secure a specific sum of money constituted a demand for ransom, making the purpose of the kidnapping clear. The defenses of denial and alibi were correctly rejected for being weak and uncorroborated against the positive identification by the victims. The presence of minors among the victims made the duration of detention inconsequential. The penalty was properly modified to reclusion perpetua without parole eligibility, in accordance with Republic Act No. 9346 , which prohibits the death penalty. The Court also modified the awarded damages, setting civil indemnity, moral damages, and exemplary damages at P100,000.00 each for every victim, with legal interest.