People vs. Deduyo

G.R. No. 138456
Johnny kidnapped for ransom by Deduyo, detained with threats; ransom demanded, Deduyo arrested, trial in absentia; Supreme Court affirmed guilt, modified penalty to death.
kidnapping for ransom false pretenses deprivation of liberty

Case Digest (G.R. No. 138456)

Facts:

People of the Philippines v. Rolando Deduyo y Piryo alias "Batman" and Isagani Manago (Acquitted), G.R. No. 138456, October 23, 2003, the Supreme Court En Banc, Per Curiam. The appellant is Rolando Deduyo alias "Batman"; the People of the Philippines is the appellee; Isagani Manago was co-accused and was acquitted by the trial court.

On January 30–31, 1994, the 16‑year‑old victim, Johnny Mauricio, was induced by the appellant to leave Antipolo allegedly to fetch a baggage at the airport; instead he was taken to a small house in Bagong Ilog, Pasig, left under the guard of a man known as Bayani (who brandished a knife and threatened that people who entered would not come out alive), and was prevented from leaving. That same afternoon Johnny’s mother, Salvacion Mauricio, received a ransom letter demanding P100,000 (or at least P50,000) and instructing her where to bring the money; police surveillance subsequently apprehended Isagani near the Antipolo Church and, following information he gave, the police arrested the appellant in Pasig.

An information for kidnapping for ransom (Art. 267, Revised Penal Code, as amended by RA 7659) was filed against the appellant and Isagani; both pleaded not guilty at arraignment on June 7, 1994. The appellant escaped during a mass jailbreak from Rizal Provincial Jail on July 29, 1994; trial therefore proceeded in absentia. The Regional Trial Court (RTC), Branch 71, Antipolo, found Manago not proven guilty but convicted Deduyo beyond reasonable doubt of kidnapping for ransom and sentenced him to reclusion perpetua in a decision dated February 20, 1998 (promulgated March 30, 1998). The warden notified the court of the appellant’s re‑arrest and detention on February 19, 1998.

The appellant appealed to the Supreme Court from the RTC decision...(Pro-only)

Issues:

  • Was the trial in absentia of the appellant proper under the Constitution and rules of criminal procedure?
  • Was the evidence sufficient to convict Rolando Deduyo beyond reasonable doubt of kidnapping for ransom?
  • Was the penalty imposed properly fixed, and is the death penalty proper under the law as applicable to this case?
  • Was the trial court’s refus...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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