G.R. No. 247339 - Department of Agrarian Reform vs. Lapanday Foods Corp.

The case involves appellant Franco Darmo de Guzman, charged with kidnapping and serious illegal detention pursuant to Article 267 of the Revised Penal Code.
An Information was filed on October 28, 2010, alleging that on October 6, 2010, appellant, by means of machination, willfully and unlawfully kidnapped and detained minor AAA for eight days, thereby depriving him of his liberty.
During arraignment, appellant pleaded not guilty. Trial was subsequently conducted on the merits, and the trial court (RTC, Makati City, Branch 140) found him guilty beyond reasonable doubt.

On October 1, 2010, while in Isetann Mall, Recto, Manila, appellant approached minor AAA for assistance after his personal belongings were stolen.

Appellant requested AAA’s help to withdraw money at a bank due to the theft of his identification cards.
AAA agreed and later accompanied appellant to Citibank; however, identification issues prevented the withdrawal.

On October 6, 2010, a group composed of appellant, AAA, CCC (AAA’s brother), and a friend named Vincent proceeded to Citibank, Paseo de Roxas, Makati.

AAA and CCC were promised rewards by appellant to assist him in filling up banking forms for an ATM application.
Appellant entered the bank while the others waited at a nearby fast food restaurant.
After a delay and confusion over their whereabouts, CCC and Vincent later learned AAA and appellant had not returned.

Based on AAA’s testimony, appellant later enticed the minor to travel to Cogeo, Antipolo under the pretense of opening a vault.
Once in an old decrepit house, AAA was detained from October 6 until October 14, 2010.
Appellant, portraying himself as a sultan with bodyguards, threatened AAA, ordering him not to leave the premises.
During the detention, AAA was forced to sell his cellphone for money to provide sustenance and was coerced into performing sexual acts under the guise of “missions.”
A neighbor’s intervention, prompted by a news report on the missing minor, led to police involvement and eventually to AAA’s rescue.

The prosecution presented the victim, his father (BBB), and his brother (CCC) as witnesses, along with testimonies from arresting officers Rufino B. Almodiel, Jr. and PO1 Ger Aaron Sembrano.
AAA’s account, corroborated by his family members and the arresting officers, established that he was indeed confined and controlled by appellant in Antipolo.
Additional evidence from the scene, such as the presence of locked doors and covered windows, supported the claim of unlawful detention.

Appellant claimed that he was an unlicensed physical therapist from Baguio City, and maintained that his association with AAA began in 2009 when they met in Isetann Mall.
According to the defense, the relationship between appellant and the minor was built on friendship, not coercion.

Appellant argued that the minor voluntarily accompanied him on the trip and that his presence at AAA’s house was consensual, illustrating ordinary interactions such as cleaning, watching television, and even drinking together.

The alleged detention was a result of miscommunication, not an intentional deprivation of liberty.
There was no physical confinement since all locks in the house were broken, and AAA was free to leave whenever he wished.
The claims of sexual abuse and coercive "missions" were fabricated and inconsistent with the facts.

The RTC found appellant guilty beyond reasonable doubt based primarily on the victim’s consistent testimony and its corroboration by other witnesses, despite the defense's denial and inconsistencies in appellant’s version.
The RTC sentenced appellant to reclusion perpetua without eligibility for parole and ordered him to pay moral and exemplary damages to the private offended party.
The Court of Appeals, in its January 21, 2014 Decision, affirmed the RTC’s ruling in toto, upholding the factual findings especially regarding AAA’s deprivation of liberty.

Appellant’s appeal was considered by the Supreme Court with the primary issue focusing on whether he was guilty beyond reasonable doubt.
The Supreme Court reviewed inconsistencies in the victim’s testimony and assessed the credibility of the witnesses.
Affirming the lower courts’ findings, the Supreme Court dismissed the appeal and reiterated that the credible testimonies and circumstantial evidence were sufficient to establish the crime of kidnapping and serious illegal detention.

Whether the evidence presented sufficiently established beyond reasonable doubt that appellant unlawfully kidnapped and detained minor AAA.

Did the testimonies of the victim, his family, and the arresting officers prove the deprivation of liberty?
How significant were the inconsistencies in the victim’s testimony, and did they affect the overall credibility of the prosecution’s evidence?

Whether appellant’s defense—asserting a consensual relationship with AAA—negates the element of unlawful detention.

Can the fact that certain events appeared voluntary (e.g., accompanying appellant to the bank or to AAA’s house) be reconciled with the later detention and coercion?
Did appellant provide any corroborated evidence to support his claim that AAA was not forcibly detained?

Whether the trial court’s assessment of witness credibility should be disturbed by appellate review in the absence of substantial evidence to the contrary.

Is there a clear demonstration that the lower court overlooked or misinterpreted any significant facts or circumstances?