G.R. No. L-18760 September 29, 1966
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. KAMAD AKIRAN, ET AL., defendants. KAMAD AKIRAN, JARANG ASKALI, ALAMMARA DUMPAS and KASTIRI SAPPARI, defendants-appellants.

FACTS

An amended information for kidnapping with ransom was filed against Kamad Akiran, Jarang Askali, Jamiri Hawadji, Alammara Dumpas, and Kastiri Sappari, along with five others at large. It alleged that on July 26, 1960, in Maimbung, Sulu, the accused, armed and conspiring, kidnapped Isirani Sakili, detained him for nine hours in Bud Katinganan, and released him only after extorting a ransom of P1,000. The charge against Jamiri Hawadji was dismissed for lack of evidence. The remaining four accused pleaded not guilty. The prosecution presented the victim, Isirani Sakili, who testified that he, his brother Hadji Hassan, and his driver were stopped by armed men led by Jarang Askali while traveling. Jarang ordered Hadji Hassan to produce P1,600 for Isirani’s release. Isirani was taken to an abaca plantation and later to Jamiri Hawadji’s house, where he was released after Hadji Hassan and his father-in-law, Saddawani Sadda, gave Jarang P1,000, promising the balance the next day. Isirani and Hadji Hassan positively identified the four accused as among the kidnappers. The defense presented an alternative narrative, claiming the incident stemmed from a prior shooting of Jarang’s brother, Hayani Askali, by relatives of Isirani. They asserted that the P1,000 was a payment for hospital expenses, arranged through an intermediary, Jamiri Hawadji, to settle the matter and prevent a complaint, not a ransom. The trial court found the four accused guilty and sentenced them to death.

ISSUE

The primary issue hinges on the credibility of witnesses and whether the facts establish the crime of kidnapping for ransom under Article 267 of the Revised Penal Code, as amended by Republic Act No. 1084.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s findings on credibility, noting that appellate courts generally will not disturb such findings as the trial court is in a better position to observe the witnesses. The defense’s claim that the money was for hospital expenses was rejected. The Court found that the actions of the accused—armed, stopping the truck, demanding money for release, and detaining the victim—constituted kidnapping for ransom. The Court ruled that the money demanded and received as a condition for release constitutes “ransom” under the law, regardless of any other alleged motive. The alibi of Kamad Akiran was rejected for being uncorroborated and in the face of positive identification. The positive identification of all accused by the prosecution witnesses prevailed over the defense’s denials and claims. However, for lack of the necessary votes to impose the death penalty, the Court modified the sentence from death to reclusion perpetua.