G.R. No. 193833 - People vs. PO1 Froilan L. Trestiza, et al.

Appellant PO1 Froilan L. Trestiza, P/S Insp. Lorieman L. Manrique, and Rodie J. Pineda were accused and charged on November 20, 2002, in several criminal cases, primarily Criminal Case No. 02-3393 for Kidnapping for Ransom in Makati City.
The kidnapping charges alleged that on November 7, 2002, the accused, all armed and conspiring with one PO2 Reynel Jose, unlawfully kidnapped Lawrence Yu and Maria Irma Navarro with the purpose of extorting ransom of Php 1,000,000.00.
Additional related cases included Criminal Case No. 02-3394 for Illegal Possession of Firearm against Trestiza, and Criminal Cases Nos. 03-766 and 04-1311 for Robbery against the accused.

Trestiza was acquitted of illegal possession of firearms (Case No. 02-3394) on April 15, 2004.
The prosecution sought to withdraw the kidnapping charge, reclassifying it to robbery and grave threats following a preliminary investigation. This move was opposed by private complainants and the trial court denied the motion to withdraw the kidnapping charge.
The trial court set arraignment and a series of motions including Omnibus Motion by Trestiza challenging various aspects of the case.

On November 7, 2002, Yu and Navarro were at the Where Else Disco in Makati City when they were accosted by men identified later as the accused.
Yu and Navarro were forcibly taken; Navarro was handcuffed and both were deprived of liberty inside vehicles driven or occupied by the accused.
The accused demanded ransom and allegedly took cash, jewelry, watches, and cell phones from the victims.
Victims were threatened not to report the incident, with menacing references made to family members.

Navarro identified Pineda as a personal acquaintance and recognized Manrique and others as police officers involved.
Yu testified regarding the physical abduction, the presence of firearms, the cruel treatment and threats, and the ransom demand.
An entrapment operation was conducted resulting in the arrest of Pineda with recovered items from victims.

Defense claimed a legitimate police buy-bust operation was conducted against alleged drug dealers Yu and Navarro.
It was argued that Pineda reported Yu's illegal activities and coordinated with the accused police officers for law enforcement.
The accused were portrayed as acting in official capacity with tactical coordination and proper process.

The trial court found the prosecution witnesses credible and the defense testimonies not credible, pointing out inconsistencies and lack of corroboration for the police operation claim.
The trial court cited the unreliability of the Pre-Operation/Coordination Sheet presented by the defense.
The accused were found guilty beyond reasonable doubt of Kidnapping for Ransom and sentenced to reclusion perpetua along with damages awarded to Navarro and Yu.

The Court of Appeals affirmed the trial court decision, holding that all elements of kidnapping for ransom were present.
Trestiza's argument that he was merely the driver and not a conspirator was rejected based on witness identification and conduct.

Trestiza filed an appeal raising issues including the credibility of Lawrence Yu due to his later arrest for illegal drugs, claimed limited participation, and improper arrest.
The Supreme Court ruled Trestiza's arrest legal objections waived due to failure to timely object.
The Court upheld the conviction, emphasizing the credibility of witnesses and noting that being police officers does not exempt liability when acting beyond official functions.
Civil liabilities were imposed jointly and severally.

Whether the arrest of Trestiza without warrant was lawful.
Whether the accused committed the crime of kidnapping for ransom despite being police officers.
Whether the accused's participation was limited to a mere driver without involvement in the conspiracy.
Whether the charges of kidnapping for ransom should have been downgraded to robbery and whether the trial court erred in rejecting the motion to withdraw the kidnapping information.
Credibility of the prosecution witnesses, particularly Lawrence Yu, in light of his later arrest for drug-related offenses.
Whether the trial court and appellate court erred in convicting the accused beyond reasonable doubt of kidnapping for ransom.