G.R. No. L-11210; May 30, 1961
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CALIXTO MAMALAYAN, ET AL., defendants. CALIXTO MAMALAYAN, VICENTE CABRERA, TELESFORO TALATALA and MARIANO PANGANIBAN, defendants-appellants.

FACTS

The appellants, along with others, were charged with Kidnapping and Serious Illegal Detention under Article 267 of the Revised Penal Code, as amended, for the kidnapping of Chinese merchant Ng Poi Gong to extort a P100,000 ransom. On July 19, 1955, the victim, her driver Dionisio Alcazaren, and companion Margarita Diego were intercepted in their jeep in Canlubang, Laguna. Armed men, identified as appellants Vicente Cabrera, Telesforo Talatala, and Mariano Panganiban, boarded the vehicle. Diego managed to escape and report the crime. Alcazaren was later released with instructions to convey the ransom demand. The kidnappers took Ng Poi to a remote area where she was held blindfolded for four days before being rescued by PC soldiers. The trial court convicted appellants Calixto Mamalayan, Cabrera, Talatala, and Panganiban as principals and sentenced them to death, recommending executive commutation to life imprisonment as the ransom was not paid and no physical injury was inflicted.

ISSUE

Whether the guilt of the appellants for the crime of Kidnapping and Serious Illegal Detention was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The legal logic rests on the conclusive establishment of the appellants’ criminal participation through both direct and circumstantial evidence. The prosecution evidence, deemed credible by the trial court, included the positive identification of appellants Cabrera, Talatala, and Panganiban by the victim and her driver during the forcible seizure and detention. The Court emphasized that the findings of the trial court on witness credibility are generally binding. Furthermore, the appellants’ own conduct after the crime constituted compelling circumstantial evidence of guilt. Specifically, Cabrera hid from and fired upon PC officers attempting to question him, Mamalayan evaded and fired at a patrol, and Talatala was found to have absented himself from his home to hide. This flight and resistance to lawful arrest are indicative of a guilty conscience. The Court also dismissed a joint motion for new trial based on a witness’s recantation, finding the recantation unreliable and insufficient to overturn the original, freely given testimony that positively identified the appellants. The penalty imposed was in accordance with the applicable law, Article 267 of the Revised Penal Code, as amended.