Case Digest (G.R. No. 168446)
Facts:
People of the Philippines v. Ernesto Cruz, Jr. y Concepcion and Reynaldo Agustin y Ramos, G.R. No. 168446 (formerly G.R. Nos. 144174-75), September 18, 2009, Supreme Court En Banc, Peralta, J., writing for the Court.On the evening of August 23, 1998, Atty. Danilo Soriano, a Legal Officer of Del Monte Philippines, was returning from his farm in Masuso, Pandi, Bulacan. He asked his caretaker, Reynaldo Agustin (appellant), to have his son drive him to the jeepney stop; Agustin instead insisted on driving Soriano on his motorbike. Near the jeepney stop Agustin stopped beside a parked stainless owner-type jeep in which three men were seated and one stood outside. Agustin signaled and told Soriano to board; Agustin introduced one of the men, Ernesto Cruz, Jr. (appellant), as his compadre and then left. While on the road, Cruz placed his arm around Soriano, displayed a gun and announced a hold-up; Soriano’s belongings and cash were taken and he was brought to a hut where he was detained for about a week under armed guard.
After the abduction Cruz demanded ransom and allowed Soriano to send two letters and a ransom note to his family. Monitoring of the ransom pay-off led PAOCTF operatives to arrest Cruz and co-accused Enrique Avendano on August 29, 1998 while they were carrying the ransom parcel and a cellular phone; the operatives then located Soriano at Cruz’s fishpond/huts, rescued him, and in the ensuing encounter killed one of the guards, Narciso Buluran, and recovered weapons and the ransom money. An Information charging Kidnapping and Serious Illegal Detention (Art. 267, RPC as amended by R.A. No. 7659) and Robbery (Art. 294, RPC as amended) was filed on September 22, 1998 against Cruz, Agustin and others.
At arraignment the principal accused pleaded not guilty. At trial the prosecution presented Soriano and police witnesses; the defense presented accused testimonies including Cruz’s claim that Soriano had staged the kidnapping and Agustin’s claim that he merely accompanied Soriano and had no knowledge of the crime. On May 25, 2000, the Regional Trial Court (RTC), Branch 78, Malolos, Bulacan convicted Cruz and Agustin of Kidnapping and Serious Illegal Detention and convicted Cruz of Robbery; Allen Francisco was acquitted. The RTC imposed death on Cruz and Agustin for kidnapping and ordered damages.
Because the RTC imposed death, the case was appealed to the Supreme Court; following this Court’s administrative change under People v. Mateo and A.M. No. 00-5-03-SC (permitting intermediate review), the case was transmitted to the Court of Appeals (CA). On April 8, 2005 the CA affirmed the RTC decision in toto but certified and elevated the entire records to the Supreme Court for final review and disposition. The Supreme Court received brie...(Subscriber-Only)
Issues:
- Should the Court disturb the RTC’s factual findings (credibility determinations) on the witness testimonies and circumstances of the case?
- Did the prosecution prove beyond reasonable doubt that appellants Cruz and Agustin are guilty of Kidnapping and Serious Illegal Detention (Art. 267, RPC, as amended) and that Cruz is guilty of Robbery (Art. 294, RPC, as amended), including whether Agustin was a principal by indispensable cooperation and whether Cruz’s "kidnap-me" defense negates deprivation of liberty?
- May the death penalty imposed b...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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