G.R. No. 175602 - People vs. Valdez

On February 3, 2004, the Supreme Court rendered a decision affirming the conviction of appellants Francisco Juan Larraaga, Josman Aznar, Rowen Adlawan, Albert Caao, Ariel Balansag, and the Uy brothers (James Anthony and James Andrew) for:

Special complex crime of kidnapping and serious illegal detention with homicide and rape (Criminal Case No. CBU-45303)
Simple kidnapping and serious illegal detention (Criminal Case No. CBU-45304)

For CBU-45303: All except James Anthony Uy were sentenced to death by lethal injection; James Anthony Uy, a minor at the time, was sentenced to reclusion perpetua.
For CBU-45304: The same appellants sentenced to reclusion perpetua except James Anthony Uy, sentenced to twelve (12) years prision mayor (maximum) to seventeen (17) years reclusion temporal (medium).

Appellants were ordered to jointly and severally pay civil indemnity, temperate damages, moral damages, and exemplary damages in connection with each case.

On March 23, 2004, the Uy brothers filed a motion for reconsideration asserting:

James Andrew Uy was a minor (under 18) at the time the offenses occurred (July 16, 1997).
The identity of the woman’s dead body found was never conclusively established, and requested exhumation for DNA testing.

Their motions were consolidated with those of their co-appellants.
The Court, after thorough review, denied all motions on July 21, 2005, except the claim regarding James Andrew’s minority was left unresolved.

Secure and submit a clear and legible certified copy of James Andrew Uy’s Certificate of Live Birth from the City Civil Registrar of Cotobato and the National Statistics Office.
File extensive comments on the minority issue.

On November 17, 2005, the Solicitor General submitted comments including certified birth certificates bearing a birth date of October 27, 1979.
This established James Andrew Uy was 17 years and 262 days old on July 16, 1997, the date the crimes were committed.
The Solicitor General recommended reducing James Andrew’s penalties on account of minority:

In CBU-45303, death penalty reduced to reclusion perpetua.
In CBU-45304, reclusion perpetua reduced to prision mayor (12 years maximum) to reclusion temporal (17 years medium).

Whether the death penalty and other penalties imposed on James Andrew Uy should be reduced due to his minority (being under eighteen years old) at the time of the commission of the crimes;
Whether the privileged mitigating circumstance of minority under Article 68 of the Revised Penal Code applies in this case;
Whether the evidence presented, particularly James Andrew Uy’s birth certificates, sufficiently establishes his minority at the time of the offense;
Whether the penalties imposed were proper considering the application of the Indeterminate Sentence Law and the relevant provisions of the Revised Penal Code.