GR 208441; (July, 2017) (Digest)
G.R. No. 208441 July 17, 2017
People of the Philippines, Plaintiff-Appellee vs. Zenaida Fabro or Zenaida Manalastas y Viñegas, Accused-Appellant
FACTS
Accused-appellant Zenaida Fabro, the aunt of the 9-year-old victim AAA, was charged with Serious Illegal Detention. The prosecution established that on March 2, 2006, Fabro fetched AAA from her elementary school in YYY, Pampanga, under the pretense of having permission from the child’s mother and teacher. Instead of returning AAA home, Fabro brought her to a house in Nueva Ecija. For four days, despite AAA’s pleas and phone calls from her parents begging for her release, Fabro refused to let the child go home. AAA was eventually rescued by police operatives on March 5, 2006.
The defense presented a different narrative, claiming Fabro brought AAA to Nueva Ecija with the mother’s consent to help resolve a personal dispute with her husband. She alleged AAA willingly accompanied her and that there was no intent to detain. The Regional Trial Court convicted Fabro of Serious Illegal Detention and sentenced her to reclusion perpetua, a decision affirmed by the Court of Appeals.
ISSUE
Whether the prosecution proved beyond reasonable doubt all the elements of Serious Illegal Detention under Article 267 of the Revised Penal Code.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court meticulously applied the elements of the crime. First, it was undisputed that Fabro was a private individual. Second, she deprived AAA of her liberty by taking her from school and keeping her in Nueva Ecija for four days against her will, as proven by AAA’s credible testimony detailing her pleas to go home and Fabro’s refusal. Third, this deprivation was illegal, as the initial consent from the school teacher was vitiated by Fabro’s fraudulent intent to detain, and any alleged parental consent was convincingly rebutted by the prosecution’s evidence.
Crucially, the fourth element was present: the victim was a minor. Under Article 267, when the victim is a minor, the duration of detention becomes immaterial. The offense is classified as “serious” by the mere fact that the detainee is a minor. The Court found Fabro’s claim of good faith and lack of intent to detain unconvincing, as her actions—ignoring the child’s and the parents’ desperate requests for her return—belied such an assertion. The trial courts’ factual findings on witness credibility were accorded finality. Thus, all elements of Serious Illegal Detention were proven beyond reasonable doubt.