Case Digest (G.R. No. L-59604)
Facts:
The People of the Philippines v. Victorio Pia y Bayhon, Gaudencio Lamangan y Saria, Venancio Pia y Bayhon, Diosdado Anciado y Amora, Mario Garcia y Umali, and Eduardo Vina y Montemayor, G.R. No. 59604, November 14, 1986, the Supreme Court En Banc, Paras, J., writing for the Court. The case reached the Court on automatic review following the imposition of the death penalty by the Court of First Instance of Cavite against Gaudencio Lamangan.On the evening of December 28, 1977, Juanito Chua and his wife Elma Deato Chua were accosted near their residence at Dimasalang, Imus, Cavite: two assailants forced them into a car, pointed a gun at Juanito and a knife at his wife, bound them, and carried Juanito to a hut where he was detained. The kidnappers demanded a ransom of P100,000, later agreeing to accept P18,000; the wife was released to secure the money for a delivery in Zapote, Las Piñas. Juanito Chua was rescued by the Philippine Constabulary on January 3, 1978.
An information charging Kidnapping and Serious Illegal Detention (Art. 267, Penal Code, as amended) was filed on March 28, 1978. Of the persons implicated, two (Emiliano del Rosario and Federico Camia) were at large; of the six accused initially in custody, five reportedly escaped from the provincial jail during trial proceedings. The trial was suspended as to the fugitives; it proceeded against Lamangan, Diosdado Anciado and Mario Garcia. Anciado surrendered March 21, 1979, and Garcia surrendered June 11, 1979. The trial court found Lamangan guilty as principal of kidnapping and serious illegal detention and sentenced him to death; it convicted Anciado and Garcia as accessories and imposed prison terms. Because a death sentence was imposed on Lamangan, that judgment was certified for automatic review by the Supreme Court.
In his appeal, Lamangan raised several assignments of error but chiefly contended that his extrajudicial confession ...(Subscriber-Only)
Issues:
- Was the accused-appellant Gaudencio Lamangan’s extrajudicial confession admissible in evidence?
- Did the prosecution establish beyond reasonable doubt that Lamangan directly participated in the kidnapping and serious illegal detention of Juanito Chua?
- If guilty, was the death penalty properly imposed on Lamangan under Article 267 o...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)