Case Digest (G.R. No. 199710) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. PO3 Julieto Borja (G.R. No. 199710, August 2, 2017), the accused-appellant, PO3 Julieto Borja of the Philippine National Police, was charged with kidnapping for ransom under Article 267 of the Revised Penal Code. On May 26, 2004 at approximately 10:10 a.m., in Brgy. Central, Diliman, Quezon City, Borja and an unidentified companion forcibly abducted victim Ronalyn G. Manatad by grabbing her right forearm and pushing her into a gray van. Her friend escaped and alerted Ronalyn’s mother, Adelina. While driving the victim around Quezon City, one captor—Major Clarito—demanded P200,000 from her brother, Edwin G. Silvio, later reduced to P100,000. Silvio contacted Sergeant Abet Cordova of the National Anti-Kidnapping Task Force (NAKTAF), which staged an entrapment at the Wildlife Park along Quezon Avenue. At 3:00 p.m., Borja received the marked money from Silvio and was arrested; police seized from him a .9 mm pistol, a cell phone, a wallet, and the rans... Case Digest (G.R. No. 199710) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident and Abduction
- On May 26, 2004 at about 10:00 a.m., PO3 Julieto Borja grabbed Ronalyn G. Manatad by the right forearm as she walked with Vicky Lusterio along Agham Road, Diliman, Quezon City, and forced her into a gray van with three other men.
- Lusterio escaped and informed Ronalyn’s mother, Adelina Manatad. Borja and his companions drove the victim around Quezon City for several hours.
- Ransom Demand and Entrapment
- A kidnapper calling himself Major Clarito contacted the family, initially demanding ₱200,000 and later reducing it to ₱100,000. Edwin G. Silvio, the victim’s brother, negotiated under the guidance of Sergeant Abet Cordova of NAKTAF.
- At 3:00 p.m., Edwin placed the money in an SM plastic bag at the Wildlife Park on Quezon Avenue. Borja accepted the bag and was immediately arrested; police recovered a .9 mm pistol, Borja’s cellphone, wallet, and the ransom.
- Non-Rescue and Subsequent Events
- Ronalyn, still in the van, heard her captors curse her for alerting NAKTAF. She was then taken to the Philippine Drug Enforcement Agency and charged with illegal sale of shabu.
- She was convicted of violating Republic Act No. 9165 and incarcerated in the Women’s Correctional Facility, Mandaluyong.
- Procedural History
- May 28, 2004 – Information filed for kidnapping under Article 267, RPC; Borja pleaded not guilty. RTC Branch 76 found him guilty on October 20, 2008 and sentenced him to reclusion perpetua.
- March 14, 2011 – Court of Appeals affirmed with modification (₱50,000 civil indemnity; ₱50,000 moral damages). Borja appealed to the Supreme Court, which resolved the case on August 2, 2017.
Issues:
- Whether PO3 Borja is guilty beyond reasonable doubt of kidnapping for ransom under Article 267 of the Revised Penal Code.
- Whether the victim’s subsequent arrest and conviction under RA 9165 negates Borja’s criminal liability for kidnapping.
- Whether Borja’s status as a police officer precludes prosecution for kidnapping.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)