G.R. No. 11686 - People vs Cardona

Appellants Maritess Ang and Pablo Estacio, Jr. were initially charged with kidnapping for ransom and later with kidnapping with murder.
The offenses arose from an incident that occurred on or about October 10–11, 1995, in Quezon City, Philippines.
A subsequent amendment included an additional accused, Hildo Sumipo, though he was later discharged as a state witness.

On the evening of October 10, 1995, Maritess Ang, Estacio, and Sumipo convened at Casa Leonisa Bar where they were to meet the victim, Charlie Mancillan Chua.
Maritess allegedly indicated an intention to “settle her debt” with the victim and hinted at “kidnapping” him.
After the victim’s arrival, the group boarded his car. Maritess occupied the seat beside him, while Estacio and Sumipo took positions in the back.
Estacio produced a gun and ordered the victim to pull over; subsequently, the victim was forcibly removed from the car, bound, and gagged by Maritess, while Estacio and Sumipo maintained control of the situation.

The group transported the victim from Quezon City to various locations in Bulacan including San Jose del Monte and Malinta.
En route discussions revealed plans to kill the victim; Estacio intimated that killing him would preclude any possibility of revenge.
At a later stage, the group initiated a ransom demand—first set at P15,000,000, then reduced incrementally to P10,000,000 and finally to P5,000,000—with instructions for the victim’s mother to leave money in a garbage can near a Pizza Hut.

At the secluded site, after removing the victim from the vehicle and in the presence of escalating tensions, Estacio and Maritess are implicated in the actual killing of the victim by stabbing him with a fan knife.
Estacio later telephoned the victim’s mother and admitted to killing the victim, which prompted the recovery and identification of the victim’s remains.
Testimonies from Sumipo, the victim’s mother, witnesses at various locations, and forensic evidence (including identification through dental records) substantiated the sequence of events.
Maritess’s subsequent communications and alleged admissions, including letters from prison, contributed further evidence to her participation in the crime.

The Regional Trial Court (RTC) of Quezon City found both Estacio and Maritess guilty of “kidnapping on the occasion of which the victim was killed,” sentencing them to death and ordering payment of actual, moral, and exemplary damages.
The case was automatically reviewed and then referred to the Court of Appeals following applicable jurisprudence, where the conviction was affirmed with modifications.
The evidentiary findings from the RTC regarding the demeanor and testimonies of witnesses were accorded substantial respect by the appellate courts.

Whether the acts of binding, gagging, and transporting the victim sufficiently proved the element of kidnapping as distinct from the commission of murder.
Whether the evidence supported that the kidnapping was a contemplated and intended objective rather than an incidental act to facilitate murder.

Whether the charge of “kidnapping with murder” was appropriate given that the act of kidnapping did not demonstrate an intention to detain or lock up the victim for an appreciable period.
The issue of whether identifying the crime as a special complex crime improperly required proving each separate element (kidnapping and murder) with equal precision.

Whether the discharge of Sumipo as a state witness was justified in view of the conditions established for his admission.
Whether reliance on his testimony was appropriate in convicting Maritess Ang, considering his state witness status and subsequent corroboration of the events.

Whether the original imposition of the death penalty was proper in light of the amendment of the crime designation and the later enactment of Republic Act No. 9346 prohibiting the death penalty.
Whether any errors or irregularities in trial proceedings would merit reversal of conviction or modification of the sentence imposed.