GR 90021; (May, 1991) (Digest)
G.R. No. 90021 ; May 8, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGARDO LIM Y DE GUZMAN and RODOLFO RAMIREZ Y VALENTINO, defendants-appellants.
FACTS
On August 20, 1981, Robina Gokongwei and Celina Ngochua were kidnapped in Quezon City by a group of men, including Bayani Lasian, Florito Darusin, and Arturo Sarabia. The victims were taken to Calamba, Laguna, where a ransom demand was made to John Gokongwei. Negotiations ensued, and on August 24, the victims were transported from Calamba to Manila in a car driven by a “new guy.” They were eventually rescued from a motor lodge in Ermita, Manila, on August 26, 1981. Military operatives captured Lasian and Sarabia, while appellants Edgardo Lim and Rodolfo Ramirez later voluntarily surrendered.
An information was filed charging Lim and Ramirez with kidnapping for ransom. The Regional Trial Court convicted them as principals, sentencing them to reclusion perpetua. Both appealed, arguing insufficient evidence and violations of constitutional rights.
ISSUE
The core issue is whether the guilt of appellants Edgardo Lim and Rodolfo Ramirez for the crime of kidnapping for ransom was proven beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted both appellants. For appellant Rodolfo Ramirez, the prosecution failed to present any witness who positively identified him as a participant in the kidnapping. The only evidence against him was an extrajudicial confession (Exhibit “H”) obtained without the assistance of counsel, in violation of his constitutional rights, rendering it inadmissible. Without this confession and lacking any credible identification, his guilt was not established.
For appellant Edgardo Lim, the Court found the identification by the victims, Robina and Celina, to be unreliable. Their testimonies contained material inconsistencies regarding their opportunity to see and identify the driver during the tense, nighttime transfer from Calamba. The affidavit of arrest stating Lim’s alleged verbal admission was also deemed inadmissible as it was not properly presented or authenticated in court. Furthermore, the alleged conspiracy between Lim and Ramirez was not proven, as no evidence connected Lim to the planning or execution of the kidnapping prior to the August 24 transfer. The prosecution’s evidence failed to meet the required standard of proof beyond reasonable doubt. The Court also noted the disturbing absence of the other identified kidnappers from trial, implying possible extrajudicial measures. Consequently, the appellants were acquitted and ordered immediately released.