Case Digest (G.R. No. L-27352)
Facts:
People of the Philippines v. Ruben Ablaza, G.R. No. L-27352, October 31, 1969, the Supreme Court En Banc, Per Curiam.In an information filed in the Court of First Instance of Rizal (Crim. Case No. 13526), Ruben Ablaza (defendant-appellant) and two unnamed co-accused (John Doe and Peter Doe) were charged with kidnapping with serious illegal detention, alleged to have occurred on or about 22 March 1963 in Makati, Rizal. The complaint was brought by Annabelle Huggins (the complainant and lone prosecution witness), who testified to two separate abduction incidents: one in November 1962 and another on 22 March 1963.
According to the prosecution, in November 1962 Ablaza forcibly took Annabelle from Caloocan to a house in Hagonoy, Bulacan, where she was raped and later rescued; a criminal case for forcible abduction with rape was filed against Ablaza in the Court of First Instance of Bulacan and was pending. On 22 March 1963, Annabelle testified she was seized while sweeping in Makati by two men, placed into a taxicab in which Ablaza was waiting, had her head pressed to the floor and mouth covered, and was moved between houses of Ablaza’s compadres and then to Bulacan, where she was recovered at the Malolos municipal building; she said she was detained about a week and guarded to prevent escape.
Ablaza testified in his own defense, claiming a prior consensual elopement with Annabelle in November 1962 and that, on March 1963, he responded to a letter (Exhibit 1) from Annabelle asking him to get her; he said she voluntarily entered the taxi and agreed to go to Malolos to have the pending complaint dropped, but that Constabulary men and her relatives then took her away at the municipal building. The authorship of Exhibit 1 was not proven at trial.
On 7 March 1967 the Court of First Instance of Rizal convicted Ablaza of kidnapping with serious illegal detention, found the aggravating circumstance of use of a motor vehicle, and sentenced him to death. The trial court’s verdict rested on its credibility assessment, finding Annabelle’s testimony more truthful and convincing than Ablaza’s.
Because a death sentence was imposed, the case ...(Subscriber-Only)
Issues:
- Should the Court disturb the trial court’s credibility-based factual findings and verdict convicting Ablaza?
- Was Ablaza properly convicted of kidnapping with serious illegal detention under Article 267 of the Revised Penal Code rather than of abduction with rape?
- Was the aggravating circumstance of use of a motor vehicle proven and properly considered in...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)