G.R. No. 256720 - Maibarara Geothermal, Inc. vs. Commissioner of Internal Revenue

The case involves the crime of kidnapping with murder committed against Chan Teng, a Chinese businessman from Ozamis City.
Thirteen defendants were charged for conspiring to kidnap Chan Teng with the intent to extort ransom, with the act culminating in his death from injuries inflicted during his detention and recapture.

On May 25, 1950, at about 9:00 p.m., Chan Teng, returning from business transactions, was accosted at the corner of Teodora Alonso and Soler streets by Gregorio Gonzales and Cenon Reyes, who falsely identified themselves as police officers investigating alleged communistic activities.
Chan Teng was forcibly driven away in an automobile driven by Apolinario Pelaez, after being misled about being taken to Camp Crame, and was ultimately taken to an isolated house on M. de la Cruz Street, Pasay City, owned by Benito Camaya.

At the isolated residence, Chan Teng was restrained—his hands tied to a cot and his feet chained—and was fed minimal sustenance (coca-cola and bread).
An escape attempt by Chan Teng the following night was brutally quashed by Ildefonso Santos and Federico Badeo, who recaptured him and tightened his bonds.
On May 28, 1950, transfer of Chan Teng took place when Ging Sam, along with Claro de la Cruz and Nicolas Cruz, carried the still chained victim into the luggage compartment of a Packard car, subsequently transporting him to another rented house at No. 13 Anak Ng Bayan Street, San Francisco del Monte.

The disappearance of Chan Teng was first reported by his wife on the morning of May 26, in combination with a note written in Chinese that revealed a ransom demand of P50,000.
The investigation was enhanced by a second note indicating Chan Teng’s location in an air raid shelter, leading to the eventual discovery of his body showing signs of violence, ligature marks, contusions, and head wounds—medical findings that testified to his death from intracranial and meningeal hemorrhage.
Key prosecution evidence arose from eyewitness testimonies (including that of Apolinario Pelaez, the driver, and others such as Co Che, the caretaker) and written confessions from several defendants.

Of the thirteen defendants charged, five (including Ildefonso Santos and Ong Giok Siu) were not apprehended at trial, while the eight available were found guilty.
Although many defendants admitted to their involvement up to a point, most contended that they acted as mere tools without full knowledge of the conspiracy’s purpose.
The evidence, including the synchronization of events and cross-confirmation by co-accused, indicated a clear pattern of complicity and collective criminal planning.

Testimonies from multiple witnesses (Apolinario Pelaez, Benito Camaya, and others) provided details of the abduction, transport, and confinement of Chan Teng.
The prosecution also introduced written confessions that, although challenged as being extorted under duress, were admitted by the trial court based on corroborative testimony.
The defendants’ own statements attempted to limit their roles to participation without full knowledge of the alleged conspiracy, often attributing the primary orchestration to still-at-large conspirators (e.g., Ong Giok Siu, Nicolas Cruz, Claro de la Cruz).

After the discovery of Chan Teng’s body, the criminals dispersed rapidly. Some, such as Arturo Basa, fled or surrendered later when arrest was imminent; others went into hiding in various locations across the country.
Additional evidence through subsequent testimonies and demonstrations of their flight (e.g., Ging Sam’s sudden departure to Cagayan) corroborated the prosecution’s narrative of a well-coordinated criminal act.

Whether to give more credence to the testimonies of the prosecution witnesses than to those of the defense.
The admissibility and probative value of the written confessions, considering claims they were extorted through third-degree methods.

Whether the various acts committed by the defendants sufficiently establish their roles as active participants in the kidnapping and the subsequent murder of Chan Teng.
The divergence between the defendants’ admissions and their attempts to minimize their awareness or involvement in the overall conspiracy.

Whether the facts and the individual acts can collectively be seen as an implied agreement or concerted plan (conspiracy) to effectuate the kidnapping for ransom and murder.
The legal interpretation of conspiracy under Article 8 of the Revised Penal Code, particularly without the need for a formal written or expressed agreement.

Whether the most culpable defendants should receive the capital punishment and if the imposition of reclusion perpetua for others is justified by their lesser role in the conspiracy.
The proper distinction between those fully responsible for orchestrating the crime and those whose participation was more peripheral.