G.R. No. L-27352 October 31, 1969
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUBEN ABLAZA, defendant-appellant.

FACTS

This is an automatic review of a decision from the Court of First Instance of Rizal convicting Ruben Ablaza of kidnapping and serious illegal detention and sentencing him to death. The information alleged that on or about March 22, 1963, in Makati, Rizal, the accused, conspiring with others, willfully kidnapped and detained Annabelle Huggins, a 20-year-old female, against her will, with the aggravating circumstance of using a motor vehicle.
The prosecution’s case, presented through complainant Annabelle Huggins, established that in November 1962, Ablaza forcibly took her from Caloocan City to Hagonoy, Bulacan, where he criminally abused her, leading to a pending case for forcible abduction with rape in Bulacan. On March 22, 1963, while that case was pending, Huggins was sweeping in front of her aunt’s house in Makati when two men grabbed her and forcibly took her to a taxicab where Ablaza was waiting. Inside the cab, her head was pressed down and her mouth covered. She was initially brought to a house in Caloocan, then moved to another house where she was kept for a week. Later, Ablaza took her to Malolos, Bulacan, to persuade her to drop the charges. There, she was rescued by her uncle and Constabulary men. She testified she was constantly guarded to prevent escape.
The defense, presented solely by accused Ruben Ablaza, claimed that in 1962, he and Huggins were sweethearts who eloped because she complained of maltreatment by her aunt. They stayed in Hagonoy, Bulacan, until found by police, leading to the abduction with rape charge. He testified that in March 1963, he received a letter from Huggins (Exhibit “1”) asking him to fetch her from her aunt’s residence in Makati. He took a taxicab, she entered voluntarily, and they agreed to marry, but first went to Malolos to drop the case. At the municipal building, Constabulary men and her aunt arrived, and she changed her mind.

ISSUE

Whether the trial court was correct in giving more weight to the testimony of the complainant and in finding the accused guilty of kidnapping and serious illegal detention, sentencing him to death.

RULING

Yes, the trial court’s decision is affirmed. The Supreme Court upheld the trial court’s findings on witness credibility, noting the rule that appellate courts will not disturb factual findings unless the trial court overlooked, misunderstood, or misapplied some fact of weight. The trial judge, having observed the witnesses’ demeanor, was in a better position to gauge credibility. The complainant’s testimony was coherent, plausible, and unshattered by cross-examination, and no motive was shown for her to falsely testify, especially since she had married and would want to avoid public exposure. Her testimony was compelled only by a warrant for her arrest.
The crime committed is kidnapping and serious illegal detention under Article 267 of the Revised Penal Code, as the essential element of deprivation of liberty was duly proved. The fact that other crimes like rape may have been committed during the detention is immaterial to this prosecution; the kidnapping was consummated when the victim was restrained. The main purpose of the detention was to coerce her into withdrawing previous charges, obstructing justice, with rape being incidental.
The defense’s claimed letter from the complainant was not proven authentic, as authorship was not established, and the accused did not show familiarity with her handwriting.
The aggravating circumstance of use of a motor vehicle was properly considered, as it was established by the complainant’s declaration and the accused’s own admission that he took her away in a taxicab.
The offense, attended by one aggravating circumstance (use of motor vehicle) with no mitigating circumstance, warrants the penalty in its maximum period. Therefore, the death penalty imposed by the lower court is confirmed.