Case Digest (G.R. No. L-6244)
Case Digest (G.R. No. L-6244)
Facts:
The People of the Philippines v. Aurelio Soriano and Rafael Garcia, G.R. Nos. L-6244 and L-6245. August 30, 1955, the Supreme Court En Banc, Padilla, J., writing for the Court.The respondents in the criminal information were Aurelio Soriano (alias Beriong) and Rafael Garcia (alias Feling), charged with kidnapping. After trial, they were found guilty, sentenced to suffer reclusion perpetua with accessory penalties, and ordered to indemnify the heirs of Juan Saraos and Leocadio de la Cruz. The defendants appealed to the Supreme Court.
The prosecution’s narrative was that on the evening of 8 May 1950 Soriano and Garcia, armed with a carbine and pistol respectively, went to the house of Juan (alias Tomas) Saraos in barrio Raniag, Santiago, Isabela, and called him out; they then did the same to Leocadio de la Cruz. The two victims were taken to the schoolhouse at Bugallon where the accused summoned Atanacio Caliboso, the assistant barrio lieutenant, and turned custody over to him and to rural policeman Lope Cadavis, claiming to be Constabulary (G-2) operatives; Soriano and Garcia left but returned early the next morning, removed the two men, led them to the provincial road and put them aboard an army weapons carrier; the victims have not been seen since.
The appellants offered an alibi/mitigating narrative: they had been committed to the municipal jail of Echague on 23 March 1950 on a robbery charge (later dismissed), and were turned over to the Philippine Ground Forces (PGF) camp at Echague on 12 May 1950. Documentary records were introduced to this effect. The prosecution countered with testimony and other evidence that, notwithstanding the commitment, the appellants had been seen in Santiago on several occasions between March and May and were engaged by the Army to investigate crimes and disappearances in the province (the Court noted the related People v. Dionisio Francisco matter).
Multiple witnesses placed the appellants at the acts complained of: Antonio Saraos (son of Juan), Atanacio Caliboso (assistant barrio lieutenant), Lope Cadavis (rural policeman), Gregoria de la Torre (wife of Leocadio), and Pacita de la Cruz (daughter of Leocadio). The record, however, showed numerous material contradictions among those witnesses on critical points (who was present, whether appellants were alone or together, whether weapons were carried, whether reports were made contemporaneously), inconsistent prior sworn statements versus trial testimony, and substantial delay in reporting the alleged abductions to police (many reports were not made until April 1951). An alleged admission by Soriano to Estefanio Novisteros was not corroborated.
The trial court convicted; on appeal to the Supreme Court the Justices reviewed the testimonial conflicts, documentary evidence of prior custody and Army employment, the absence of proved motive, and surrounding circumstances suggesting hostility between the appellants and an organization called the “Santiago Defenders.” After weighing credibility, the Supreme Court reversed the conviction and acquitted the appellants. The appeal was resolved by this decision of the Court (G.R. Nos. L-6244 and L-6245).
Issues:
- Did the prosecution prove beyond reasonable doubt that Aurelio Soriano and Rafael Garcia committed the kidnapping of Juan Saraos and Leocadio de la Cruz?
- If proof was insufficient, should the conviction be reversed and the appellants acquitted?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)