Case Digest (G.R. No. 248456) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Tyrone Dela Cruz y Resurreccion and Sandy Viaesa (G.R. No. 248456, August 16, 2022), the Supreme Court, En Banc, reviewed an appeal from the Court of Appeals which had affirmed the November 17, 2017 Decision of the Regional Trial Court (Branch 92, Calamba, Laguna) convicting appellants Tyrone Dela Cruz y Resurreccion and Sandy Viaesa for Kidnapping for Ransom under Article 267 of the Revised Penal Code. The Information, filed on December 16, 2013, alleged that on or about August 9, 2013, at approximately 11:00 p.m. in Barangay Pansol, Calamba, Laguna, the accused conspired with others to kidnap spouses Jason Edward Tay Huang and Elisa Dela Cruz Huang for the purpose of extorting a ₱30,000,000 ransom later reduced to ₱867,000. On August 10, Elisa was released in Cavite to secure payment; she negotiated the amount in Camp Crame, then proceeded to the South Luzon Expressway (SLEX) where she dropped the money near a Petron station. Members of the Phil Case Digest (G.R. No. 248456) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On December 16, 2013, the Laguna Provincial Prosecutor charged Tyrone Dela Cruz y Resurreccion (Dela Cruz), Sandy Viaesa (Viaesa), Jezreel Jimmy Cuevas and a John Doe with kidnapping Spouses Jason Edward Tay Huang and Elisa Dela Cruz Huang in Calamba, Laguna on August 9, 2013 for ransom (initial demand ₱30 million, reduced to ₱867,000).
- Dela Cruz and Viaesa pleaded not guilty; Cuevas remained at large. Despite the spouses executing affidavits of desistance, RTC Branch 92 proceeded to trial.
- Prosecution Evidence
- PCI Jeffrey Fallar (PNP-AKG) received the report on August 9, 2013. On August 10, the kidnappers released Elisa in Cavite to raise the ransom. In Camp Crame, under police watch, Elisa negotiated a ₱867,000 payoff and was escorted to SLEX.
- Police observed a white Honda Civic (Plate WKV-152) tailing Elisa. At a Shell station, its occupants alighted and changed seats, then followed Elisa to a Petron station, where Viaesa retrieved the dropped ransom. Jason was released later that evening.
- Investigation linked the Civic to Dela Cruz via dealer Jun Cacanando and Facebook photos. PCI Jonel Guadalupe, PSI Nestor Acebuche, SPO4 Jaybruce Gadit and PO3 Maleo Manzano positively identified Dela Cruz and Viaesa at the Shell station and in Barangay Sibulan, Nagcarlan, Laguna.
- Defense Evidence
- Dela Cruz and Viaesa denied involvement.
- Barangay Chairman Ariel Barrios testified that operatives questioned Viaesa on September 25, 2013 about his link to Dela Cruz, threatened a warrant if he did not cooperate, but obtained no admission.
- Lower Courts’ Rulings
- RTC Decision (Nov. 17, 2017): Convicted Dela Cruz and Viaesa of kidnapping for ransom (Art. 267, RPC); imposed reclusion perpetua; ordered joint and several payment of ₱867,000 actual damages, ₱75,000 civil indemnity, ₱75,000 moral damages, ₱30,000 exemplary damages plus 6% interest.
- CA Decision (Mar. 20, 2019): Affirmed the RTC in toto, holding the circumstantial evidence sufficient despite the spouses’ desistance.
Issues:
- Whether the prosecution established Dela Cruz and Viaesa’s guilt beyond reasonable doubt for kidnapping for ransom under Article 267 RPC without the Spouses Huang’s direct testimony.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)