Case Digest (G.R. No. 90021)
Facts:
People of the Philippines v. Edgardo Lim y De Guzman and Rodolfo Ramirez y Valentino, G.R. No. 90021, May 08, 1991, Supreme Court First Division, Gancayco, J., writing for the Court.The criminal action arose from the abduction of Robina Gokongwei and Celina Ngochua on August 20, 1981. The two women and their driver were taken from Quezon City and transported to a sugarcane field in Calamba, Laguna; the kidnappers demanded ransom (initially P7,000,000 later reduced to P1.5 million). The victims were moved among several hiding places; tape-recorded exchanges and telephone contacts with John Gokongwei were used in ransom negotiations. Military operatives eventually rescued the victims in Manila on August 26, 1981; Bayani Lasian and Arturo Sarabia were captured. Other suspects (including Florito Darusin and Mario Suelto) were alleged to have been arrested by military authorities but later were reported dead or missing.
An information was filed in the Regional Trial Court (RTC), National Capital Judicial Region, Quezon City, charging Edgardo Lim and Rodolfo Ramirez with kidnapping for ransom. At arraignment both pleaded not guilty and the case proceeded to trial. The RTC, by decision dated May 10, 1988, convicted both appellants of kidnapping for ransom and sentenced them to reclusion perpetua and ordered indemnity of P50,000 each to the victims.
Both defendants appealed to the Court below (the appeal reached the Supreme Court as the present appeal). Ramirez challenged the admission and weight of his alleged extrajudicial confession (Exhibit H) and the sufficiency of positive identification. Lim raised several assignments of error: the credibility of the victim-witness identifications, the admission of Ramirez’s extrajudicial confession against him, the admission of an arrest affidavit by Sgt. Miranda, and lack of proof of conspiracy with Ramirez. The Supreme Court reviewed the trial record, testimony about the nighttime circumstances o...(Pro-only)
Issues:
- Was Rodolfo Ramirez’s extrajudicial confession admissible against him when taken without the assistance of counsel in custodial interrogation?
- If admissible, could Ramirez be convicted solely on that confession absent corroboration of corpus delicti?
- Could Ramirez’s extrajudicial confession be admitted or used against Edgardo Lim?
- Were the victim-witnesses’ identifications of Edgardo Lim sufficiently reliable to support conviction given the nighttime circumstances and trial inconsistencies?
- Was there sufficient proof of a conspiracy between Lim...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)