Case Digest (G.R. No. 174659)
Facts:
On December 13, 1999, Ma. Teresa Basario took her two-year-old son Christopher to a McDonald’s outlet in Binondo, Manila. While Teresa and her sister Zenaida were ordering food, Christopher followed Zenaida but soon disappeared from their sight. Despite frantic searches and police reports, the child remained missing. Teresa publicized Christopher's disappearance through media, but received no serious leads until February 25, 2001, when she was contacted by a woman with a Muslim accent demanding PHP 30,000 for Christopher’s return. Subsequent communications led Teresa to travel to Mindanao with a team from the Presidential Anti-Organized Crime Task Force (PAOCTF) and an undercover police officer who posed as her niece. On April 7, 2001, in Iligan City, Teresa met the accused, sisters Raga Sarapida Mamantak and Likad Sarapida Taurak, who claimed custody of Christopher and eventually returned him to Teresa upon receiving the ransom payment. Christopher was unable to recognize
Case Digest (G.R. No. 174659)
Facts:
- Circumstances of the Kidnapping
- On December 13, 1999, at about 3:00 p.m., Ma. Teresa Basario went to a McDonald's outlet in KP Tower, Binondo, Manila, with her two-year-old son Christopher and elder sister Zenaida.
- While Teresa and Christopher were sitting, Christopher followed Zenaida to the counter and suddenly disappeared from Teresa’s sight.
- Despite frantic searches inside and outside the premises, Christopher was not found. The disappearance was reported to the police, and Teresa sought public help through TV and radio.
- Teresa received no information for months, but in February 2001, she received ransom calls from a woman sounding Muslim, demanding P30,000 for Christopher’s release.
- The woman instructed Teresa to get a recent photo of Christopher, which she obtained from Jalal Restaurant at the Muslim Center in Quiapo, Manila.
- Teresa coordinated with the Presidential Anti-Organized Crime Task Force (PAOCTF), which organized a plan with Police Officer (PO)3 Juliet Palafox to act as her niece for a sting operation.
- On April 7, 2001, in Iligan City, Lanao del Norte, the two accused, Raga Sarapida Mamantak and Likad Sarapida Taurak, met Teresa and PO3 Palafox at Pitang’s Carinderia. Taurak claimed custody of Christopher and initially resisted handing him over without ransom.
- Eventually, Taurak brought Christopher to the carinderia, and upon sight, Teresa wept but the child no longer recognized her, speaking only a Muslim dialect.
- Mamantak and Taurak demanded ransom money, which PO3 Palafox paid; immediately, the PAOCTF arrested the two women.
- Defense of the Accused
- Taurak claimed she found Christopher wandering alone in Divisoria Market and took care of him, intending to find his family. She brought him home and later to the police outpost but kept him after no one claimed him.
- She claimed to have arranged the meeting with Teresa only to return Christopher after verification.
- Mamantak testified she was in Nunungan, Lanao del Norte at the time of abduction and coincidentally encountered Taurak and Christopher only at the carinderia on April 7, 2001, denying any complicity.
- Proceedings and Lower Courts’ Findings
- The trial court found both accused guilty beyond reasonable doubt of kidnapping for ransom, sentencing them to reclusion perpetua and ordering them to pay PHP50,000 civil and PHP50,000 moral damages.
- The Court of Appeals affirmed the conviction but modified the penalty from reclusion perpetua to death, stating the demand for ransom warranted the death penalty before its abolition.
- The case was elevated to the Supreme Court for final review.
Issues:
- Whether Mamantak and Taurak were guilty beyond reasonable doubt of kidnapping for ransom as charged.
- Whether the demand for P30,000 constituted ransom qualifying the crime for the death penalty under Article 267, Revised Penal Code as amended.
- The proper penalty to be imposed considering the abolition of the death penalty by RA 9346.
- Proper award of damages based on the circumstances of the case, including civil, moral, and exemplary damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)