People of the Philippines, Plaintiff-Appellee, vs. Benjamin Olidan y Erlandez, Crispin Araneta y Pelaez, Lynfer Bicodo y Baylon, Rogelio Caloring, Annabelle Olidan y Araneta, Godofredo Navanes y Lorenzo, PO1 Jose Lonmar Zapatos y Fiel, and PO1 Antonio Castillo y Domingo, and Rey Alada [At Large], Accused; Benjamin Olidan y Erlandez, Accused-Appellant.
FACTS
The case stemmed from an Amended Information charging Benjamin Olidan and his co-accused with Kidnapping for Ransom under Article 267 of the Revised Penal Code. The charge alleged that on August 30, 2005, the accused, conspiring and using firearms, kidnapped three minor children (AAA, BBB, CCC) and their nanny, Eulalia Cuevas, and demanded ransom for their release. The victims were on their way to school in a Ford Escape when three men in police uniforms flagged down and commandeered the vehicle, transferring the victims to a maroon Nissan Urvan and blindfolding them. They were detained in a room described as an old bathroom. The kidnappers contacted the children’s mother, DDD, demanding a PHP 50,000,000.00 ransom and threatening to kill the children if she reported to the police or failed to pay. Following a tip, police from the PNP-PACER conducted surveillance and a rescue operation at a house on Peñafrancia St., Payatas, Quezon City, where they rescued the victims and arrested Benjamin Olidan, his wife Annabelle Olidan, and Crispin Araneta. Other accused were arrested in a follow-up operation or surrendered. During trial, the victims identified the accused as their kidnappers and caretakers at the safe house. The accused pleaded not guilty. The Regional Trial Court found them guilty, a decision affirmed by the Court of Appeals. Benjamin Olidan appealed to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of accused-appellant Benjamin Olidan for the crime of Kidnapping for Ransom.
RULING
The Supreme Court DENIED the appeal and AFFIRMED the conviction of Benjamin Olidan for Kidnapping for Ransom. The Court found that all elements of the crime were proven beyond reasonable doubt: (1) the accused were private individuals; (2) they kidnapped or detained the victims; (3) the act deprived the victims of their liberty; and (4) it was committed for the purpose of extorting ransom. The testimonies of the victims, who positively identified Olidan as one of their captors who gave them food and water while detained, were credible and consistent. The defense of denial and alibi offered by Olidan was weak and could not prevail over the positive identification. The Court also upheld the finding of conspiracy among the accused, as their collective actions demonstrated a common purpose to kidnap for ransom. The penalty imposed was reclusion perpetua without eligibility for parole, as the prescribed penalty of death could not be imposed due to Republic Act No. 9346. The Court ordered Olidan to pay each victim PHP 100,000.00 as civil indemnity, PHP 100,000.00 as moral damages, and PHP 100,000.00 as exemplary damages, with interest at 6% per annum from finality of judgment until full payment.
