Title
People vs. Jatulan y Ponce
Case
G.R. No. 171653
Decision Date
Apr 24, 2007
A man was convicted of kidnapping a 5-year-old for ransom, resulting in a sentence of reclusion perpetua without parole.
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Case Digest (G.R. No. 171653)

Facts:

  • Judith Jatulan y Ponce, also known as "Lito," was accused of kidnapping for ransom.
  • The incident occurred on February 13, 1995, in Teremil Subdivision, Mambugan, Antipolo, Rizal.
  • Jatulan, along with three co-accused—Paul Liporada y Honorio, Meil Liporada y Honorio, and Gilbert Denyega y Musico—allegedly kidnapped five-year-old Karwin Amado.
  • The Information filed under Article 267 of the Revised Penal Code claimed the accused conspired to unlawfully take Karwin to extort a ransom of P250,000.
  • On March 21, 1995, all four accused were arraigned and pleaded "not guilty."
  • The prosecution presented witnesses, including the victim, his mother, and police officials.
  • The defense argued that Jatulan deceived the minor co-accused into participating in the crime.
  • On September 3, 2002, the Regional Trial Court (RTC) convicted Jatulan and sentenced him to death by lethal injection, while acquitting the three minors due to lack of evidence.
  • The case was reviewed by the Supreme Court and transferred to the Court of Appeals (CA).
  • On December 16, 2005, the CA affirmed the RTC's decision, leading to the current appeal.

Issue:

  • (Unlock)

Ruling:

  • The Court affirmed the conviction of Judith Jatulan y Ponce for kidnapping for ransom, finding him guilty beyond reasonable doubt.
  • The penalty of death by lethal injection was modified to reclusion perpetua without eligibilit...(Unlock)

Ratio:

  • The Supreme Court determined that the prosecution proved the elements of kidnapping for ransom as defined under Article 267 of the Revised Penal Code.
  • The Court noted that the crime's essence is the actual deprivation of the victim's liberty, which was evident in this case.
  • Karwin Amado was lured by Jatulan under false pretenses and was not allowed to leave when he wanted to go home.
  • The Court rejected Jatulan's defense that Karwin voluntarily accompanied him, emphasiz...continue reading

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