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