Case Digest (G.R. No. L-4287)
Facts:
The People of the Philippines v. Ging Sam alias Taba, et al., G.R. No. L-4287, December 29, 1953, the Supreme Court En Banc, Per Curiam, writing for the Court.The prosecution charged thirteen defendants with kidnapping with murder in the Court of First Instance of Manila for the abduction, detention for ransom and fatal beating of Chan Teng, a Chinese merchant who visited Manila in May 1950. Five of the thirteen defendants remained at large when the case was tried; eight were apprehended, tried, convicted by the trial court and sentenced each to death and to pay P5,000 indemnity to the heirs. The convicted defendants appealed to the Supreme Court.
The evidence at trial showed that on the night of May 25, 1950, Chan Teng was accosted at Teodora Alonso and Soler streets by Gregorio Gonzales and Cenon Reyes, falsely represented as police, forced into a car driven by Apolinario Pelaez and taken to an isolated house in Pasay (Benito Camaya’s house) where he was bound, chained and guarded. A ransom note demanding P50,000 was delivered to Chan’s uncle. On May 28 the victim was moved—allegedly by Ging Sam and companions—in the luggage compartment of a Packard to a house in San Francisco del Monte; his body was later found dumped in an air-raid shelter with injuries causing intracranial and meningeal hemorrhage.
Police investigation led to arrests in June 1950; witnesses who testified for the prosecution included Pelaez (the driver), Benito Camaya (householder where the victim was detained), Co Che (caretaker where the body was found), and others. Several defendants executed written confessions during police investigation (Dee Chee Ping, Lee Tao, Yao Ling, Gregorio Gonzales, Federico Badeo, Cenon Reyes), which the defense later alleged were obtained by third-degree methods; Ging Sam refused to sign a written confession but testified at trial. The trial court accredited the prosecution’s witnesses, found conspiracy and participation established, convicted eight defendants and sentenced them to death; some defendants (including Lee Tao) contested the verdicts and sentences on appeal.
On appeal to the Supreme Court (the defendants “interposed the present appeal”), the Court reviewed credibility findings, the sufficienc...(Subscriber-Only)
Issues:
- Did the evidence, including the alleged extrajudicial confessions, prove beyond reasonable doubt that the appellants conspired to kidnap and murder Chan Teng and that each appellant was criminally responsible for the offense?
- Were the extrajudicial written confessions, some repudiated as having been extorted by third-degree methods, essential to sustaining convictions and, if so, were they admissible?
- Were the penalties imposed by the trial court appropriate as to each appellant, and should any...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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