G.R. No. 216065 APRIL 18, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. REYNANTE MANZANERO y HABANA, ET AL., Accused, ARTHUR FAJARDO y MAMALAYAN, Accused-Appellant.

FACTS

Accused-appellant Arthur Fajardo, along with several others, was charged with Kidnapping for Ransom and Robbery. The prosecution established that on November 23, 2003, victim Tony Chua was forcibly taken by men identifying themselves as NBI agents as he was about to enter his car in Manila. He was handcuffed, blindfolded, and detained in a safe house where his personal belongings were taken. His captors demanded a $3 million ransom from his family. Tony was detained for over a month, during which he was able to identify Fajardo as one of his abductors. He eventually escaped on December 30, 2003. Several accused later surrendered to authorities.
Fajardo denied involvement, claiming he only learned of the kidnapping after a raid on his house and that he voluntarily surrendered. He challenged the credibility of his extrajudicial confession and the victim’s identification. The Regional Trial Court convicted him, a decision affirmed with modification by the Court of Appeals. Fajardo appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Arthur Fajardo for the crimes of Kidnapping for Ransom and Robbery.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. The Court held that all elements of Kidnapping for Ransom under Article 267 of the Revised Penal Code were proven: (1) the victim was deprived of liberty; (2) the act was committed by simulating public authority; (3) the deprivation lasted for more than three days; and (4) ransom was demanded. The victim’s credible and categorical testimony provided direct evidence of Fajardo’s participation. He consistently identified Fajardo in open court as one of the men who handcuffed and abducted him.
The Court rejected Fajardo’s defenses. The victim’s identification was deemed reliable, as he had a clear view of his abductors during the initial seizure and later during his prolonged detention when his blindfold was occasionally removed. His testimony was straightforward and consistent. The defense of alibi and denial could not prevail over this positive identification. Furthermore, the conspiracy among the accused was evident from their collective actions in seizing, detaining, and demanding ransom for the victim. The Court ruled that even disregarding the extrajudicial confessions of co-accused, the victim’s testimony alone was sufficient to sustain the conviction beyond reasonable doubt.