Title
People vs. Domasian
Case
G.R. No. 95322
Decision Date
Mar 1, 1993
An 8-year-old boy was kidnapped in 1982; ransom note linked to a physician. Court upheld kidnapping conviction, citing conspiracy, credible witnesses, and handwriting analysis.

Case Digest (G.R. No. 163786)
Expanded Legal Reasoning Model

Facts:

  • Parties and background
    • Victim: Enrico Paulo Agra, an 8-year-old boy and son of Dr. and Mrs. Enrique Agra, owners of a local hospital in Lopez, Quezon.
    • Accused:
      • Pablito Domasian, a private individual.
      • Dr. Samson Tan, then a resident physician at the Agra family hospital.
  • Abduction, rescue, and trial initiation
    • Kidnapping incident (March 11, 1982)
      • Domasian lured Enrico under pretense of obtaining his father’s signature on a medical certificate.
      • The boy was moved by tricycle to Calantipayan, forced into a minibus at gunpoint, threatened to stop crying, and transported to Gumaca, the public market, then to San Vicente—detained for about three hours.
    • Rescue and identification
      • Jeepney driver Alexander Grate grew suspicious of the man-child pair, alerted two barangay tanods, and pursued them.
      • The kidnapper fled, leaving Enrico behind; the boy rejoined his parents en route home.
    • Ransom note and forensic evidence
      • At 1:45 PM, Dr. Enrique Agra received a note demanding ₱1 million for Enrico’s release, under threat of killing him.
      • The note was submitted to the police, referred to the NBI, and the NBI handwriting expert concluded the note was written by Dr. Tan.
    • Photo identification
      • Enrico and his classmate positively identified Domasian from a folder of photographs at the police station.
    • Trial and defenses
      • Both accused were charged with kidnapping with serious illegal detention.
      • Domasian’s alibi: attending a mahjong game and later visiting an optical clinic with his wife.
      • Tan’s alibi: being in Manila at the time of the incident.

Issues:

  • Credibility and evidence
    • Whether the trial court properly assessed and preferred the testimony of the victim and independent witnesses over the accused’s alibi witnesses.
    • Which handwriting expert (NBI vs. PC/INP) should be credited in identifying the ransom note’s author.
  • Legal classification and liability
    • Whether the crime is kidnapping with serious illegal detention or falls under a lesser offense such as grave coercion.
    • Whether sending the ransom note constituted an “impossible crime” under Article 4 of the RPC.
    • Whether a conspiracy existed between Domasian and Tan.
    • Whether constitutional rights were violated by warrantless arrest, alleged torture, or seizure of documents without a warrant.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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