Case Digest (G.R. No. 178300)
Facts:
People of the Philippines v. Domingo Reyes y Paje, Alvin Arnaldo y Avena and Joselito Flores y Victorio, G.R. No. 178300, March 17, 2009, Third Division, Chico‑Nazario, J., writing for the Court.The Information charging the appellants with the special complex crime of kidnapping for ransom with homicide was filed on August 11, 1999, in the Regional Trial Court (RTC), Branch 12, Malolos, Bulacan. The prosecution alleged that on the night of July 16, 1999 the Yao family was abducted from their poultry farm in San Jose del Monte, Bulacan; that appellants and several cohorts blindfolded, transported and detained some family members in a safe‑house; that a ransom of P5,000,000.00 was demanded; and that two victims (Chua Ong Ping Sim and Raymond Yao) later died of asphyxia by strangulation. Appellants pleaded not guilty at arraignment and trial ensued.
The prosecution presented eyewitness testimony of family members Jona Abagatnan, Robert Yao and Yao San, police witnesses and two attorneys who assisted during custodial interrogations, together with documentary exhibits including sworn statements, sketches, death certificates and the written extra‑judicial confessions of appellants Arnaldo and Flores. The defense offered testimony and exhibits asserting alibis, claims of frame‑up, and that Arnaldo had been an “asset” of the Presidential Anti‑Organized Crime Task Force (PAOCTF) and that some confessions were coerced.
On February 26, 2002, the RTC convicted the three appellants as principals of kidnapping for ransom with (double) homicide and imposed the death penalty on each, plus awards of civil indemnity, moral damages and costs. Because of the imposition of death, the case was initially elevated for automatic review to the Supreme Court but was remanded to the Court of Appeals pursuant to People v. Mateo. The Court of Appeals, in a decision promulgated August 14, 2006, affirmed the conviction but reduced the penalty from death to reclusion perpetua (without possibility of parole), lowered civil indemnity and ordered exemplary damages; its resolution denying reconsideration was dated October 18, 2006. Appellants filed a Notice of Appeal ...(Subscriber-Only)
Issues:
- Was the admission into evidence of the extra‑judicial confessions of appellants Arnaldo and Flores constitutionally proper?
- Did the prosecution prove the identity, conspiracy and guilt of appellants beyond reasonable doubt such that their convictions should stand?
- Were the penalties and damages imposed by the RTC and the Court of Appeals proper in light of subsequent statutory chan...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)