G.R. No. 172693 - People vs. Solangon

On February 7, 2000, an Information was filed against appellant Ricardo Solangon, Apolonio Haniel, and other John Does.
The accusatory portion alleged that on or about March 26, 1992, in Sitio Calamintao, Barangay Alacaak, Sta. Cruz, Occidental Mindoro, the accused, acting in band and with conspiratorial intent, kidnapped for ransom Libertador F. Vidal – also known as Ador – and subsequently killed him with evident premeditation, treachery, and abuse of superior strength.
Only appellant Solangon was apprehended; the other accused remained at large.
During his arraignment, Solangon pleaded not guilty.

Libertador F. Vidal, a mayoralty candidate for Sta. Cruz during the local elections, was traveling with his sister Eden Vidal and other board member candidates after a campaign trail.
The convoy, consisting of four vehicles, was stopped at Balao river by seven armed men, including the appellant identified as Ka Ramil, who claimed to be members of the New People’s Army (NPA).
The armed group ordered everyone to get out of the vehicles and line up, aiming their firearms at the campaigners.
Upon identifying Vidal, the appellant tied his hands with a nylon rope, and the group demanded a campaign fee of P50,000.00 and the release of Vidal.
Failing in the ransom negotiation, the bandits forcibly abducted Vidal and took him to a mountainous area.

On April 4, 1992, Marilou Vidal (the victim’s wife), together with Rodrigo Alcantara and Lando Mendoza, delivered the ransom money totaling P50,000.00 at Brgy. Kurtinganan, Sta. Cruz.
The bandits promised that Vidal would be released the following night, but the promise was not honored, and the victim was never seen alive again.

On July 9, 1999, around 3:00 p.m., Solangon was arrested by the PNP Mobile Group in Mamburao, Occidental Mindoro, while aboard a bus destined for San Jose, Occ. Mindoro.
During subsequent investigation, Solangon led police to a remote mountain area in Brgy. Balao, Abra de Ilog, where a shallow grave containing a skeleton (identified by relatives due to distinct features such as the forehead, chin, and dentures) was found.
The skeletal remains were accepted by the victim’s relatives as those of Libertador F. Vidal, despite the absence of DNA or dental analysis.

The appellant contended that he was not involved with the NPA and maintained an alibi, stating that on March 26, 1992, he was engaged in planting coconut trees in Sitio Langka, Abra de Ilog.
He asserted that during 1992 and 1993 he was primarily involved in farming and occasional visits to his sister’s residence in Sablayan or San Jose.
Regarding his arrest on July 9, 1999, he claimed he was merely a passenger on a bus, and his subsequent arrest was due to soldiers boarding the vehicle, not because he was involved in any crime.

On August 31, 2004, the Regional Trial Court of Mamburao, Branch 44, rendered a decision finding Solangon guilty of the complex crime of kidnapping with murder.
The court imposed the mandatory penalty of death (later subject to modification due to subsequent legal developments), along with orders to pay P50,000.00 each as civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

On appeal, Solangon argued that the act of kidnapping was absorptive in the crime of rebellion under Article 134 of the Revised Penal Code, and he questioned the evidentiary basis, particularly the identification of the skeletal remains and the admissibility of his confession.
The Court of Appeals affirmed the trial court’s ruling on the complex crime of kidnapping with murder but modified the classification by rejecting the notion that he could be deemed a political offender.

The Supreme Court reviewed the entire chain of events, the evidentiary findings, and the legal arguments made on appeal.
It was determined that the proper classification was not as a single complex crime but as two separate offenses: kidnapping for ransom and murder committed as an afterthought.
The Court emphasized that the killing of the victim was not integral to the kidnapping plan but rather occurred after the ransom negotiations, thereby necessitating the recognition of two distinct crimes.

Whether the deeds of abduction and subsequent killing of Libertador F. Vidal should be considered a complex crime of kidnapping with murder or two separate crimes (kidnapping for ransom and murder).

Whether the circumstantial evidence, including the identification of the skeletal remains and Solangon’s admissions during the investigation, sufficed to establish his guilt beyond reasonable doubt.
Whether the absence of direct eyewitness testimony to the act of killing impairs the conviction for murder.

Whether the rule stated in People v. Ramos and other precedents on the absorption of kidnapping into rebellion applies in the present circumstances, given that the kidnapping was allegedly executed for extortion purposes.
Whether the elements of kidnapping and murder, established through circumstantial evidence, meet the stringent requirements for conviction.

The appropriateness of the death penalty for the crime of kidnapping for ransom in light of Republic Act No. 9346, which prohibits its imposition.
The proper sentencing for murder committed before the effectivity of R.A. No. 7659 (The Death Penalty Law) and the applicable penalties under the Revised Penal Code.

Whether the appellant’s asserted alibi and his claim of having been arrested under duress during custodial investigation could mitigate his liability or affect the evidentiary foundation for his conviction.