G.R. No. 125498 - Rodrigo, Jr. vs. Sandiganbayan

On or about August 10, 1998, at around 1:45 a.m., a group of armed men, including accused-appellants Roderick Licayan and Roberto Lara, abducted Joseph Tomas Co and Linda Manaysay.
The kidnapping was executed with evident premeditation, using a handgun and a .38 revolver, with the purpose of extorting a ransom of P10 million.

Complainants, associated with Goodies Pares Mami House—which has branches in Valenzuela, Cubao, and Sampaloc—were intercepted while Co was supervising operations at the Sampaloc branch.
The perpetrators, having approached Co from behind without masks, forced the complainants into the rear of Co’s Toyota Tamaraw FX.
During transport, the victims’ hands were tied, their eyes taped, and caps were placed on their heads as they were taken to a safehouse in Daang Bakal, Parang, Marikina.
In the safehouse, Co and Manaysay were kept under detention and only managed to escape after approximately two hours of confinement when the guard, identified as accused-appellant Roberto Lara, fell asleep.

In the vehicle and safehouse, Co pointed to Licayan as one of the abductors.
Manaysay identified Licayan and also indicated Lara as the one who attended to their needs (e.g., bringing a container when she needed to urinate).

A police line-up was conducted at Camp Crame where the victims again pointed out the accused.
Testimonies during the trial reaffirmed that despite the inability of the complainants to describe all physical features in detail (due to circumstances like their blindfolded state), the identification was clear and convincing.

Following the victims’ escape, the case was turned over to the Presidential Anti-Organized Crime Task Force (PAOCTF), which later raided the safehouse on August 11, 1998.
During the raid, a man (Roberto Lara) was apprehended and subsequently identified through photographs and by pointing fingers to Licayan.
Both accused-appellants were then brought to Camp Crame where they were later identified by the complainants in a police line-up.
The accused asserted an alibi: Licayan claimed he was at home with an acquaintance during part of the incident and during his arrest, while Lara asserted he was at his workplace or with family members until his apprehension.

The full credence given by the trial court to the varied testimonies of the prosecution witnesses, despite noted inconsistencies.
The legality of their arrest, arguing that it was based solely on the complainants’ information without the officers’ personal knowledge, and that they were not informed of their constitutional rights during custodial investigation.
Their direct involvement in the kidnapping, contending that if guilty, their participation amounted only to that of mere accomplices rather than principal offenders, as they were not involved in formulating the criminal design.

The incident details—including the use of force, the method of detainment, and the subsequent escape of the complainants—were corroborated by multiple elements such as the victims’ testimonies, police accounts, and the method of execution of the crime.

Acquitting the accused for the crime of robbery.
Convicting them beyond reasonable doubt of Kidnapping for Ransom pursuant to Article 267 of the Revised Penal Code, as amended by R.A. 7659.

The penalty of death by lethal injection on each accused.
Joint and several liabilities for moral and exemplary damages originally set at P100,000 each to the victims, and an additional award for actual damages (P20,000 for one victim).

The appeals raised by the accused were centered on the credibility of eyewitness identification, the legality of their arrest, and the characterization of their participation in the crime.

Whether the trial court erred in giving full credence to the testimonies of the prosecution witnesses despite inconsistencies in their accounts, particularly regarding the description and identification of the accused.

Whether the accused-appellants’ arrest was illegal because it was allegedly based solely on the complainants’ information and failed to meet the requirements for warrantless arrest as enumerated in Section 5, Rule 113 of the Revised Rules of Criminal Procedure.
Whether the failure to inform the accused of their constitutional rights during the custodial investigation invalidates the arrest.

Whether, assuming the facts as presented by the prosecution are true, the accused-appellants acted only as mere accomplices (or guards) rather than direct participants in the conspiracy and execution of the kidnapping-for-ransom scheme.
Whether the acts of the accused that include guarding the victims imply knowledge of a broader criminal design and thus warrant a conviction for kidnapping for ransom, not merely as accessories.