GR 208404; (February, 2016) (Digest)
G.R. No. 208404, February 24, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. VICENTE LUGNASIN and DEVINCIO GUERRERO, Accused-Appellants.
FACTS
The prosecution’s case rested on the testimony of Nicassius Cordero, who testified that on April 20, 1999, he was abducted by armed men outside his Quezon City residence. He positively identified accused-appellant Devincio Guerrero as one who pushed him into a vehicle at gunpoint. The group transported him to Batangas, where he was detained for four days. During the ordeal, a man introduced as “Commander,” later identified as accused-appellant Vicente Lugnasin, took charge, questioned him about his family and work, and explicitly demanded a thirty-million-peso ransom for his release. Cordero was eventually released without any ransom being paid.
The defense consisted of alibi and denial. Vicente Lugnasin claimed he was first seen by Cordero only at the Department of Justice and that his arrest stemmed from other robbery cases. Devincio Guerrero, a fish vendor, asserted he was arrested without a warrant in Lucena City in 2002 and had never met Cordero prior to the trial. Both denied any involvement in the kidnapping.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellants Vicente Lugnasin and Devincio Guerrero for the crime of Kidnapping for Ransom beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court upheld the credibility of victim Nicassius Cordero’s positive identification of both accused-appellants. His testimony was found to be clear, consistent, and credible, detailing his abduction, detention, and the ransom demand. The Court emphasized that the defense of alibi and denial cannot prevail over the positive identification by the victim, especially where no ill motive was shown for the victim to falsely testify. The claim of warrantless arrest was deemed irrelevant to the determination of guilt, as any irregularity in the arrest does not affect the court’s jurisdiction or the validity of the judgment. The elements of kidnapping for ransom under Article 267 of the Revised Penal Code were sufficiently established: the accused deprived Cordero of his liberty; the deprivation was illegal; and it was carried out for the purpose of extorting ransom. The Court modified the awarded damages, imposing civil indemnity, moral damages, and exemplary damages, all with legal interest. The penalty was reduced to reclusion perpetua without eligibility for parole, conforming to Republic Act No. 9346 which prohibits the death penalty.