Facts:

The case involves Judith Jatulan y Ponce, also known as "Lito," who was accused of kidnapping for ransom. The events unfolded on February 13, 1995, in Teremil Subdivision, Mambugan, Antipolo, Rizal, where Jatulan, along with three other 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 against them under Article 267 of the Revised Penal Code stated that the accused conspired to unlawfully take Karwin against his will, detaining him in a safehouse in a mountainous area to extort a ransom of P250,000.

On March 21, 1995, all four accused were arraigned and pleaded "not guilty." The prosecution presented several witnesses, including the victim, his mother, and police officials involved in the investigation. The defense, on the other hand, claimed that Jatulan had tricked the minor co-accused into participating in the kidnapping.

On September 3, 2...

Facts:

1. Incident Details:

   • On February 13, 1995, at around 12:30 PM, in Teremil Subdivision, Mambugan, Antipolo, Rizal, Judith Jatulan y Ponce, alias "Lito," along with three other co-accused (Paul Liporada, Meil Liporada, and Gilbert Denyega), kidnapped Karwin Amado, a 5-year-old boy.
   • The kidnapping was carried out by luring Karwin with the promise of a "Shaider" toy, which they claimed was located in a mountainous area. Karwin was taken to a hut in Sitio Tagisan, Mayamot, Antipolo, Rizal, where he was detained.

2. Ransom Demand:

   • On February 14, 1995, the Amado family received a ransom note demanding P250,000 for Karwin's release. The note instructed the family to deliver the money through Karwin's sister, Karen, at a designated location near Mayamot Elementary School.

3. Rescue Operation:

   • The Presidential Anti-Crime Commission (PACC) was involved in the rescue operation. On February 15, 1995, Karen Amado, carrying boodle money, went to the designated location. The co-accused (Paul, Meil, and Gilbert) were apprehended during the operation, while Jatulan escaped.
   • On February 16, 1995, Jatulan was arrested in a nipa hut in Cogeo, Antipolo, where Karwin was rescued.

4. Trial Proceedings:

   • The Regional Trial Court (RTC) of Antipolo City found Jatulan guilty of kidnapping for ransom and sentenced him to death. The three minor co-accused were acquitted due to insufficient evidence.
   • The Court of Appeals (CA) affirmed the RTC's decision, and the case was elevated to the Supreme Court for automatic review.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Elements of Kidnapping for Ransom:

   • The prosecution successfully proved all the elements of kidnapping for ransom under Article 267 of the Revised Penal Code:
     • Jatulan, a private individual, kidnapped and detained Karwin Amado, a minor, against his will.
     • The act was illegal, and the kidnapping was carried out for the purpose of extorting ransom from Karwin's family.
     • The ransom note and the testimony of Karwin and his sister, Karen, established the intent to extort ransom.

2. Deprivation of Liberty:

   • The Court rejected Jatulan's argument that there was no deprivation of liberty, as Karwin voluntarily went with him. The Court held that the victim's voluntary action was induced by false promises, and the deprivation of liberty was evident when Karwin was not allowed to return home until the ransom was paid.

3. Ransom as a Bargaining Chip:

   • The Court emphasized that the crime of kidnapping for ransom is consummated once the ransom is demanded, regardless of whether it is actually paid. The ransom note and the boodle money operation confirmed the intent to extort ransom.

4. Penalty Modification:

   • While the crime warranted the death penalty under the law at the time of the offense, the passage of Republic Act No. 9346, which abolished the death penalty, required the Court to modify the penalty to reclusion perpetua without eligibility for parole.

5. Credibility of Witnesses:

   • The Court upheld the credibility of the prosecution witnesses, particularly Karwin Amado, who positively identified Jatulan as the perpetrator. The Court also noted that Jatulan's denial was unsubstantiated and could not outweigh the affirmative testimonies of the prosecution witnesses.

Conclusion:

The Supreme Court affirmed the conviction of Judith Jatulan y Ponce for kidnapping for ransom but modified the penalty to reclusion perpetua without eligibility for parole, in accordance with Republic Act No. 9346.