Case Digest (G.R. No. 263920)
Facts:
People of the Philippines v. Benjamin Olidan y Erlandez, G.R. No. 263920, August 14, 2024, Supreme Court Third Division, Inting, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Benjamin Olidan y Erlandez. Co-accused include Crispin Araneta y Pelaez, Annabelle Olidan y Araneta, Lynfer Bicodo y Baylon, Rogelio Caloring, Rey Alada (at large), PO1 Jose Lonmar Zapatos y Fiel, and PO1 Antonio Castillo y Domingo.An Amended Information charged the accused with Kidnapping for Ransom under Article 267 of the Revised Penal Code for the August 30, 2005 abduction of three children (ages 9–11) and their nanny, and the demand of PHP 50,000,000.00. At arraignment the named accused (except Alada, who remained at large) pleaded not guilty; at pre-trial the parties admitted the victims' minority and the territorial jurisdiction of the Regional Trial Court (RTC), Branch 225, Quezon City. Trial ensued.
The prosecution’s evidence narrated that armed men in police uniform flagged down the victims’ vehicle, forced out the driver, boarded the car, sped away, transferred the victims to a maroon Nissan Urvan, blindfolded them, and detained them in a Payatas safe house (a water-refilling store). The victims and their nanny identified several of the persons who visited and cared for them in the safe house as among the accused-appellant and co-accused. The family driver and the mother corroborated the course of events; police PNP-PACER conducted a surveillance and rescue on August 31, 2005, recovered the victims, and arrested occupants of the safe house and the van. PO1 Zapatos surrendered and, together with PO1 Castillo and an accused Caloring, executed extrajudicial confessions implicating the group. Several witnesses identified accused-appellant as a caretaker at the safe house.
The defense witnesses and several accused testified they were arrested without warrant, claimed coercion in obtaining signatures or statements, and denied participation. During trial one co-accused (Navanes) died and the RTC later ruled his criminal liability extinguished by death.
On March 26, 2013, the RTC convicted accused-appellant and several co-accused of Kidnapping for Ransom and sentenced them to reclusion perpetua, ordering damages. Appeals followed to the Court of Appeals (CA); several co-accused either had their appeals dismissed, withdrew appeals, or did not appeal, leaving accused-appellant, Caloring, and PO1 Zapatos as appellants before the CA. In its June 7, 2019 decision, the CA affirmed with modifications, convicting accused-appellant and some co-accused, increasing damages to PHP 100,000 each (including awards to Spouses ABC), and affirming the valid...(Subscriber-Only)
Issues:
- Whether accused-appellant is guilty beyond reasonable doubt of Kidnapping for Ransom.
- Whether accused-appellant may be convicted of four counts of Kidnapping for Ransom notwithstanding that only one Information was filed (duplicity and waiver).
- Whether Spouses ABC are entitled to the damages awarded by the Court of Appeals.
- Whether the penalty imposed should be reclusion perpet...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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