Case Digest (G.R. No. L-2025)
Facts:
El Pueblo de Filipinas v. Ricardo Parulan, Gloria Caballero and Crisanto Santos, G.R. No. L-2025. April 28, 1951, the Supreme Court En Banc, Pablo, J., writing for the Court.At the time of the crime, Arthur Lee (Chinese name Dy Juat Suy) was manager of the Equitable Trading Company in Manila. Gloria Caballero, a 20‑year‑old widow who worked as a hostess in gambling houses, became Lee’s paramour; Lee provided her with money and supported her lodging. Ricardo Parulan met Gloria separately and, after several social encounters, questioned Lee’s wealth and suggested a plan to kidnap Lee and extort P15,000. Gloria, believing Parulan’s first mention of kidnapping a joke, continued her relations with both men for over two months while receiving money from Lee and occasionally giving money to Parulan.
On the evening of 10 June 1947 Lee and Gloria dined together and, upon leaving, were accosted by Parulan at Gloria’s residence; Parulan, armed, forced Lee out of the Packard, ordered Crisanto Santos to take Lee’s place at the wheel, and compelled Lee and Gloria into the car. They were taken to Bambang, Bocaue, where a banca with an outboard motor was procured; Lee was stripped of shoes and clothing, threatened repeatedly to surrender P15,000, beaten, and ordered to undress and pray. Lee offered only P500; Parulan declared this insufficient, shot Lee (multiple gunshot wounds), and Paulino threw the body into the water. The group returned to Manila, later abandoned the Packard after removing radio and plates, and dispersed; Santos later removed the radio. Lee’s decomposed body was found on 18 June at Bambang, and autopsy disclosed multiple bullet wounds and fractures.
The Court of First Instance of Manila convicted Parulan and Gloria as co‑authors of kidnapping with murder and sentenced them—Parulan to death and Gloria to death; Crisanto Santos was convicted as accomplice and given the indeterminate term (minimum 8 years 1 day of prision mayor to maximum 14 years 8 months 1 day of reclusion temporal) plus indemnity and costs; Mariano Natividad, Paulino Natividad and Abelardo Desiderio were acqu...(Subscriber-Only)
Issues:
- Did the Court of First Instance of Manila have jurisdiction to try the offense charged?
- Whether the facts establish that Parulan committed the complex crime of kidnapping (secuestro) with murder and whether the killing was with alevosia.
- Whether Gloria Caballero and Crisanto Santos were co‑authors or mere accomplices, and what pena...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)