Case Digest (G.R. No. 65864)
Facts:
People of the Philippines v. Pablo Mangulabnan, G.R. No. 65864, August 16, 1991, Supreme Court Second Division, Paras, J., writing for the Court. The prosecution (plaintiff-appellee) charged several persons, including Pablo Mangulabnan (accused-appellant), Major Rolando de Guzman and others, in an information filed October 15, 1982 for Kidnapping for Ransom with Serious Illegal Detention for the abduction of 16‑year‑old Deborah Simon on March 24, 1982 and her detention until rescue on April 18, 1982. The information alleged conspiracy among the accused, use of a motor vehicle, nighttime commission, superior strength, and other aggravating circumstances.At trial in the Court of First Instance of Cotabato (Criminal Case No. 860), several co-accused gave extrajudicial confessions; one co-accused, Abdul Manabilang @ Ting, was discharged by the trial court as a state witness and later testified for the prosecution. Major de Guzman invoked military privilege and obtained a temporary restraining order from the Supreme Court in a separate petition (G.R. No. 62798), which prevented the trial court from proceeding against him; civilians successfully moved for separate trial, and the trial proceeded as to the civilian accused. Several accused escaped custody and remained at large, and others were tried in absentia only to the extent permissible.
The prosecution presented numerous witnesses including the victim Deborah Simon, her father Dominic Simon, Assemblyman Esteban Doruelo, and state witness Manabilang; Manabilang’s testimony implicated appellant Mangulabnán as an organizer/negotiator. The defense offered witnesses and an alibi for Mangulabnán, who admitted acting as a negotiator but denied participating in the kidnapping for personal gain. On October 14, 1983 the trial court convicted Pablo Mangulabnán, Arsad Ugalingan, Kadir Solaiman, Abdullah Masiri and Guiamil Bari of kidnapping for ransom with serious illegal detention and sentenced them to life imprisonment, acquitting two others charged only as accessories‑after‑the‑fact. Mangulabnán moved for a new trial based on an alleged recantation by the state witness; the motion was denied.
Several co-accused later withdrew their appeals and their convictions became final...(Pro-only)
Issues:
- Was the discharge of a co-accused as a state witness and the reliance on his testimony proper and admissible?
- Was the evidence sufficient to establish conspiracy and to prove beyond reasonable doubt that appellant Pablo Mangulabnán was guilty of kidnapping for ransom with serious illegal detention?
- Should the trial court have granted a motion for new trial based on the alleged recantation of the state witness?
- Did appellant’s alibi create ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)