G.R. No. 186472 - People vs. Siongco y Dela Cruz

On the evening of December 27, 1998, 11-year-old Nikko Satimbre, a resident of Balanga, Bataan, was induced by Antonio Siongco to board a bus bound for Pilar, Bataan, together with Siongco's friends, Marion Boton and Eriberto Enriquez. Nikko was promised a "Gameboy" and told the two would accompany him to claim it.
Siongco was known to Nikko as a former security guard in the shoe store where Nikko’s mother, Elvira Satimbre, worked.
After a stop in Pilar, the group proceeded to Mariveles, Bataan, met George Hayco, and then brought Nikko to Dinalupihan, Bataan, where he was kept overnight.
Elvira realized her son was missing around 7:00 p.m., searched for him without success, and reported the disappearance to the police.

On December 28, 1998, Enriquez and Siongco took Nikko to Bicutan, Taguig, Metro Manila.
On December 29, 1998, Siongco called Elvira, claimed custody of Nikko, and demanded a ransom of P400,000, later reduced to P300,000 after Elvira’s negotiation. Nikko spoke briefly to his mother during the call, but Siongco immediately took the phone and threatened to kill Nikko if the ransom was not paid by 6:00 p.m. the next day at Genesis Bus Station in Pasay City.
Elvira reported the kidnapping to the police that night.

On December 30, 1998, Enriquez and Siongco moved Nikko to Pateros and stayed at Heracleo San Jose’s house. They warned Nikko not to reveal he was kidnapped. Elvira missed a meeting at the designated ransom point as she was still gathering money. The captors renewed threats and tried to arrange another payment meeting which Elvira refused.
On December 31, 1998, after multiple calls and threats, Elvira agreed to meet the kidnappers at Genesis Bus Station. Nikko was allowed to speak to her and assured that he was not mistreated. Enriquez left to meet Elvira while Nikko stayed behind.
Police operatives from the Philippine Anti-Organized Crime Task Force (PAOCTF), headed by Police Senior Inspector Rodolfo Azurin, Jr., were informed and took part in the operations. Enriquez was arrested at the bus station upon taking the ransom envelope from Elvira. Siongco was arrested soon after at Heracleo’s residence where Nikko was rescued.
Following these arrests, other accused including Bonsol, Hayco, and Boton were arrested.

On January 4, 1999, an Information was filed charging Siongco, Bonsol, Enriquez, Hayco, Boton, and a John Doe with kidnapping and serious illegal detention under Article 267 of the Revised Penal Code.
The accused entered pleas of not guilty and trial commenced. Witnesses included Nikko, Elvira, Heracleo, Police Senior Inspector Azurin, Jr., and Police Superintendent Paul Tucay.
Except for Boton, all accused testified denying involvement or knowledge of the crime.
The Regional Trial Court (RTC), Branch 166, Pasig City, found Siongco, Bonsol, Enriquez, and Hayco guilty beyond reasonable doubt on November 6, 2000, sentencing them to death, and acquitted Boton. The court ordered payment of moral damages to Nikko and Elvira.
The case was automatically reviewed by the Supreme Court, which, pursuant to procedural rulings, transferred it to the Court of Appeals (CA) for intermediate review. The CA affirmed the conviction, reduced the penalty to reclusion perpetua without parole, increased moral damages, and added exemplary damages.
Siongco and Bonsol filed an appeal with the Supreme Court; Enriquez and Hayco’s conviction became final.

Appellants claimed denial of their right to competent counsel when Atty. Michael Moralde was appointed as counsel de oficio during certain hearings due to absence of their regular Public Attorney’s Office counsel.
The appointment was to avoid delays under the continuous trial system, and the court found no violation of the right to counsel.

Whether or not the elements of kidnapping and serious illegal detention were sufficiently proven beyond reasonable doubt against appellants.
Whether or not the detention of Nikko was illegal considering he allegedly voluntarily boarded the bus with the accused.
Whether or not appellants were deprived of their right to competent, independent counsel due to the appointment of a different counsel during the pre-trial and trial phases.
Proper application of penalties and awards of damages, in light of the abolition of the death penalty.