Case Digest (G.R. No. 186472)
Facts:
People of the Philippines v. Antonio Siongco y Dela Cruz, Eriberto Enriquez y Gemson, George Hayco y Cullera, and Allan Bonsol y Paz, G.R. No. 186472, July 05, 2010, Supreme Court Second Division, Nachura, J., writing for the Court.On December 27–31, 1998, 11‑year‑old Nikko Satimbre was induced by Antonio Siongco to board a bus from Balanga, Bataan, with acquaintances Marion Boton and Eriberto Enriquez on the pretext of getting a promised "Gameboy." The group travelled through Pilar and Mariveles to Dinalupihan where Nikko was kept overnight; subsequently he was moved to Bicutan and then to Pateros and Metro Manila. Nikko’s mother, Elvira Satimbre, reported him missing and on December 29 received a ransom call from a man later identified as Siongco demanding P400,000 (ultimately reduced to P300,000), threatening Nikko’s life if the ransom was not paid.
Police operatives of the Philippine Anti‑Organized Crime Task Force (PAOCTF) conducted a pay‑off operation at Genesis Bus Station, Pasay City on December 31, 1998; Enriquez was arrested while taking a brown envelope from Elvira, and Siongco was later arrested at a Pateros residence where Nikko was rescued. Follow‑up operations led to the arrest of Allan Bonsol, George Hayco, and Boton (Boton was later acquitted). Investigations and testimony by Nikko, his mother, relatives, and police officers formed the prosecution’s case.
An Information was filed January 4, 1999, charging the five named accused and a John Doe with Kidnapping and Serious Illegal Detention under Article 267 of the Revised Penal Code as amended by R.A. No. 7659. After arraignment and trial at the Regional Trial Court (RTC), Branch 166, Pasig City, the RTC (November 6, 2000) convicted Siongco, Bonsol, Enriquez and Hayco and sentenced them to death; Boton was acquitted for reasonable doubt. The case was then subject to automatic review by the Supreme Court (docketed G.R. No. 146756), but pursuant to People v. Mateo was transferred to the Court of Appeals (CA‑G.R. CR‑H.C. No. 00774) for intermediate review.
The Court of Appeals (September 20, 2007; penned by A.J. Abdulwahid) affirmed the RTC’s findings of guilt but modified the penalty to reclusion perpetua and increased awards of moral and exemplary damages (ordering P100,000 each as moral and exemplary damages, joint and solidary). Only appellants Siongco and Bonsol perfected an appeal to the Supreme Court; in a Resolution dated April 13, 2009, the Supreme Court accepted their appeal under the provisions of Sections 3 and 10 of Rule 122 and Section 13 of Rule 124 of the Revised Rules of ...(Subscriber-Only)
Issues:
- Was appellants’ right to an independent and competent counsel violated when the RTC appointed Atty. Michael Moralde as counsel de oficio during portions of the proceedings?
- Did the prosecution prove beyond reasonable doubt the elements of kidnapping and serious illegal detention under Art. 267, Revised Penal Code, as amended by R.A. No. 7659, given the claimed voluntary accompaniment of the minor victim?
- Is appellant Allan Bonsol criminally liable as a coconspirator such that it is immaterial whether he acted as principal or accomplice?
- Are the penalty and damages imposed appropriate in light of the abolition of death pen...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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