Case Digest (G.R. No. 105954-55)
Facts:
People of the Philippines, G.R. Nos. 105954-55, September 28, 1999, First Division, Ynares‑Santiago, J., writing for the Court. The decision reviews the Regional Trial Court (RTC) of Biñan, Laguna judgment in Criminal Case No. 4371‑B dated December 20, 1991, which convicted appellants to suffer reclusion perpetua.
The information charged several persons with kidnapping for ransom and serious illegal detention; of those named, only Ireneo Fajardo, Simplicio Atienza and Ruperto Fajardo were arraigned and tried, one accused died during the proceedings and the rest remained at large. The RTC acquitted Simplicio Atienza but found Ireneo and Ruperto Fajardo guilty and sentenced them to reclusion perpetua; the trial of Criminal Case No. 4371‑B had been consolidated with another case later dismissed by the lower court.
The factual core is undisputed: on November 15, 1986 Japanese executive Nobuyuki Wakaoji and his party left Canlubang Golf Club in a convoy; prosecution witness Ernesto Escobar testified that two cars overtook the convoy, two armed men approached the lead car and a third man (identified by Escobar as Ireneo Fajardo) stood by a blue Toyota Cressida as the kidnappers forced Wakaoji into it and sped away. Approximately ten days later — on November 25, 1986 — witnesses Jimmy Lasam and Mario Palig separately testified they saw Wakaoji blindfolded and with his hands tied being escorted from Benigno Lumbres’s house to a waiting white car in Talisay, Batangas; Palig also testified to a helicopter landing with Japanese nationals at the scene. The prosecution produced testimony suggesting a ransom was paid; the trial court relied on the eyewitness accounts and other evidence to conclude the victim had been detained for more than five days and to convict the two appellants.
Appellants appealed, raising seven assignments of error contesting the credibility and procurement of witnesses, admissibility of written statements of non‑testifying persons, the existence of conspiracy, positive identification, rejection of alibi, denia...(Pro-only)
Issues:
- Were the prosecution witnesses procured, perjured, or otherwise unworthy of credit so as to overturn the convictions?
- Did the trial court err in considering written statements of persons not presented as witnesses and in relying on inadmissible evidence (including newspapers) to find conspiracy or guilt?
- Were the identities of the appellants sufficiently and positively established to sustain conviction despite the defense of alibi?
- Was the denial of appellants’ motion to introduce allegedly newly discovered evidence (newspaper confessions by others) erroneous and prejudicial?
- Was the element of illegal detention (including duration of more than five days) ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)