Facts:

• Appellants Bong Chan and Elmo Chan were charged with Kidnapping and Serious Illegal Detention under Article 267 of the Revised Penal Code.
• The incident occurred on the evening of September 27, 2004, in Barangay Tawin-A-tawin, Alaminos City, Pangasinan.
• Victim Reynard P. Camba had an altercation with Melrose Libadia and her husband, Ronnie, during which Melrose's father, Elmo Chan, allegedly threatened him.
• After visiting his uncle, Ernesto Estepa, the victim left around 11:00 p.m. and was attacked by the appellants with bamboo sticks, rendering him unconscious.
• The appellants placed the victim in a sack and carried him away, depriving him of his liberty.
• The Regional Trial Court (RTC) found the appellants guilty on July 31, 2013, dismissing their defenses of alibi and denial.
• The RTC sentenced both appellants to reclusion perpetua and ordered them to pay damages to the victim's heirs.
• The appellants appealed to the Court of Appeals (CA), questioning the credibility of Ernesto's testimony and the prosecution's proof of actual confinement.

Issue:

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Ruling:

• The Supreme Court dismissed the appeal, affirming the decisions of both the RTC and the CA.
• The Court held that the prosecution successfully proved all elements of Kidnapping and Serious Illegal Detention, including actual confine...(Unlock)

Ratio:

• The Supreme Court's ruling was based on the established elements of Kidnapping and Serious Illegal Detention as defined under Article 267 of the Revised Penal Code.
• All elements were present: the appellants were private individuals, they kidnapped the victim, their actions were illegal, and the victim was detained for an extended period.
• Ernesto's testimony, which detailed the attack and subsequent actions of the appellants, was credible and sufficient to establish actual confinement.
• T...continue reading