G.R. No. L-37908 October 23, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN ONG y KHO, BIENVENIDO QUINTOS y SUMALJAG, and BALDOMERO AMBROSIO, alias “VAL”, accused, BALDOMERO AMBROSIO, Defendant-Appellant.

FACTS

On April 23, 1971, Henry Chua disappeared after being last seen with his friend, Benjamin Ong. Following a manhunt, Ong was apprehended and confessed to Chua’s murder, implicating Bienvenido Quintos, Fernando Tan, and Baldomero Ambrosio. Quintos, upon arrest, corroborated Ong’s confession and provided details, leading to the recovery of Chua’s decomposed body. Ong and Quintos were tried, convicted of murder, and sentenced to reclusion perpetua by this Court in G.R. No. L-34497, a decision which became final.
While Ong and Quintos were tried, Ambrosio remained at large until his arrest in August 1972. A separate information for Kidnapping with Murder was filed against him. At his trial, the prosecution presented evidence, including the prior confessions of his co-accused and the autopsy report, establishing that Chua was kidnapped, held for ransom, and stabbed to death. Ambrosio denied participation, claiming he was merely a driver unaware of the criminal plan.

ISSUE

The core issue is whether the guilt of accused-appellant Baldomero Ambrosio for the crime of Murder was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed Ambrosio’s conviction for Murder but modified the penalty to reclusion perpetua. The legal logic rests on the established conspiracy and the credibility of evidence against him. The Court found that the prosecution successfully proved the existence of a conspiracy among Ong, Quintos, Tan, and Ambrosio to kidnap and kill Chua for ransom. Ambrosio’s active participation was detailed in the extrajudicial confessions of his co-conspirators, Ong and Quintos, which were previously affirmed by the Court in the final and executory decision in G.R. No. L-34497. These confessions were properly admitted against Ambrosio as evidence of the conspiracy’s existence and execution, not for their truth as to his personal acts, but as corroborated by other evidence.
The Court rejected Ambrosio’s defense of being an innocent driver. His actions—helping to pull Chua from his car, driving the getaway vehicle to the secluded murder site, and his presence during the burial—were integral to the crime’s success and demonstrated shared criminal intent. The qualifying circumstance of treachery was present, as the attack was deliberate and ensured the victim had no chance to defend himself. However, the Court correctly treated the kidnapping as absorbed by the murder, convicting him of Murder alone. No aggravating circumstances were appreciated to justify the death penalty, leading to the imposition of reclusion perpetua.