Case Digest (G.R. No. 200053)
Facts:
People of the Philippines v. Alfredo Jose y Lagua Alias Jojo, Joey Jose y Matusalem, Arnold Macamus Alias Kyam or Dikiam, Fortunato Mangahas Alias Nato y Sandique, Joel Bulauitan y Macamus and John Does, Accused, Joel Bulauitan y Macamus, Accused‑Appellant, G.R. No. 200053, October 23, 2013, First Division, Reyes, J., writing for the Court.The prosecution (plaintiff‑appellee People of the Philippines) charged several persons by Information dated October 10, 2002 with kidnapping for ransom for acts allegedly committed on August 12, 2001 in Tuguegarao City, Cagayan; the named accused included Alfred Jose y Lagua, Joey Jose y Matusalem, Arnold Macamus, Fortunato Mangahas, Joel Bulauitan and unnamed John Does. Only Bulauitan and Fortunato Mangahas were arraigned; alias warrants were issued for the other co‑accused.
At trial before the Regional Trial Court (RTC), Branch 3, Carig, Tuguegarao City, the prosecution presented the testimony of the kidnap victim, Editha (Tuddao/Chua), her son‑in‑law Eric Chua, and SPO2 Jim Roger Julian, who related how two armed men entered the Chua residence, assaulted Vicente Chua, forcibly took Editha into a vehicle, blindfolded and bound her, transported her to Roxas, Isabela, and left her in the vehicle where she later freed herself and was recovered by police. Editha and Eric identified Mangahas and Bulauitan in court as two of the men who entered the gate, wielded firearms (one long, one short), dragged Editha to the vehicle and rode with her. The defense offered denial and alibi: both Bulauitan and Mangahas testified they were working in Solana, Cagayan on the relevant dates; each offered family members to corroborate.
On February 2, 2009 (amended February 4, 2009), the RTC convicted Mangahas and Bulauitan of kidnapping for ransom, sentencing them to reclusion perpetua and ordering them to pay Editha P40,000 as moral damages and P25,000 as exemplary damages (the amended judgment made the liabilities joint and several). Bulauitan filed a Notice of Appeal to the Court of Appeals (CA).
The CA, in CA‑G.R. CR‑HC No. 03812, rendered a Decision dated April 29, 2011 (opinion penned by Associate Justice Remedios A. Salazar‑Fernando, with Associate Justices Celia C. Librea‑Leagogo and Danton Q. Bueser concurring) that affirmed the RTC conviction but modified the judgment by holding the two accused not eligible for parole under the Indeterminate Sentence Law and increasing exemplary damages from P25,000 to P100,000. Bulauitan filed a notice of appeal to this Court, adopting the brief he filed before the CA.
The Office of the Solicitor General (OSG) urged dismissal of the app...(Subscriber-Only)
Issues:
- Did the RTC and the Court of Appeals err in finding Joel Bulauitan guilty beyond reasonable doubt of the crime of kidnapping for rans...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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