G.R. No. 121200 - Samedra vs. Court of Appeals

The case involves the People of the Philippines versus Roderick Licayan, Roberto Lara, and Rogelio “Noel” Delos Reyes.
In the initial trial, the Regional Trial Court (RTC) of Marikina City convicted Licayan and Lara of the crime of Kidnapping for Ransom and sentenced them to death.
The Court’s August 15, 2001 decision affirmed the RTC’s ruling but imposed a modification: the accused were ordered to pay moral damages and the award of actual damages to complainant Joseph Co was deleted.
Subsequent motions for reconsideration were filed and denied, and the decision became final and executory by November 9, 2001.

With the scheduling of the execution on January 30, 2004, further developments emerged when two co-accused were arrested:

The Public Attorney’s Office (PAO) filed an Urgent Motion to Reopen the case, which led the appellate court (by a close vote) to temporarily suspend the execution of Licayan and Lara for 30 calendar days.
On February 17, 2004, the Court granted the motion pro hac vice, remanding the case back to the RTC to receive additional evidence and to allow the trial of the newly arrested co-accused while holding that the evidence already taken for Licayan and Lara would stand.

The crimes occurred on August 10–11, 1998 during the abduction of complainants Joseph Tomas Co and Linda Manaysay at Goodies Pares Mami House in Sampaloc, Manila.
The facts narrated include:

Complainants undertook their regular rounds of inspection at various branches of the restaurant late in the evening, concluding at Sampaloc.
At around 1:30 a.m., while at the Sampaloc branch, the abductors—armed with pistols and a revolver—approached Co and Manaysay, proceeded to forcibly subdue them, and abducted them using a vehicle (Toyota Tamaraw FX).
The victims were transported to a safehouse where their personal effects (wallet, time deposit certificate, watch, jewelry, and cash) were seized.
During captivity, while their hands were tied and eyes taped, the victim provided a description and identification of one of the accused, notably Roderick Licayan, by observing both faces and later checking on their feet.

Detailed testimonies by complainant Joseph Tomas Co and Linda Manaysay established the sequence of events and identification of the abductors.
The prosecution’s evidence included:

Direct identification by the victims in a police line-up (initially by their feet, later by their faces).
Consistent recounting of their confinement, the actions of the abductors, and the manner in which they were overseen (e.g., the guard role played by Roberto Lara).

An alibi presented by Roberto Lara claiming he was at work during the incident and later fetching his child’s belongings at his uncle Pedro Mabansag’s house.
Accused Licayan asserting that he was at home and only encountered the victims upon arrest at Camp Crame.
Testimonies from co-workers (including Abelardo Ramirez and employer Florencia Lavarro Salvador) meant to corroborate Lara’s alibi.
The testimony of Delos Reyes, who claimed he was forced under duress (invoking the defense of irresistible force) when a gun was pointed at him, compelling him to guard the victims.

The RTC eventually reconvened the matter for Licayan, Lara, and Delos Reyes in light of the reopened case.
On February 17, 2009, the RTC rendered a decision convicting the accused for Kidnapping for Ransom, sentencing them to reclusion perpetua and ordering them to pay damages.
The Court of Appeals (on July 4, 2012) affirmed the RTC’s decision.
A subsequent review by the Supreme Court (in the pro hac vice proceedings) considered both the newly introduced evidence and the previously adduced testimonies, ultimately affirming the conviction while modifying the damages in conformity with recent jurisprudence and in light of Republic Act No. 9346, which prohibits the imposition of the death penalty.

Whether the identification of Licayan and Lara by the victims—initially done via observation of their feet and subsequently by their faces—was reliable and sufficient to establish their direct involvement in the abduction and ransom crime.
How inconsistencies or minor discrepancies in the victims’ recollections impact the overall credibility of their testimonies.

Whether the additional evidence, including the testimonies and affidavits of co-accused (Pedro Mabansag and Delos Reyes), constitutes “newly-discovered evidence” capable of altering the verdict.
Whether such evidence, originating from co-accused, meets the threshold of being both genuinely new and probative enough to warrant a new trial or reversal of conviction.

Whether the accused Delos Reyes successfully demonstrated that his actions during the kidnapping were performed under the compulsion of irresistible force, thereby potentially exempting him from criminal liability.
The sufficiency of his evidence to prove that he acted without free will due to an immediate and overwhelming threat, as required under Article 12, paragraph 5 of the Revised Penal Code.

Whether the separate alibi provided by Roberto Lara, supported by witness testimonies from his co-workers and employer, effectively establishes that he could not have been present at the scene of the crime.
The impact of the timing and geographic proximity between alleged alibi activities and the location of the kidnapping.