G.R. No. 208170 - People vs. Yau

Accused-appellants Petrus Yau (a.k.a. aJohna and aRickya) and Susana Yau y Sumogba (a.k.a. aSusana) were charged with Kidnapping for Ransom and Serious Illegal Detention.
The kidnapping allegedly occurred on January 20, 2004, near Shoemart Mega Mall, Mandaluyong City.
Victim Alastair Joseph Onglingswam, a U.S. lawyer and businessman, was taken while riding a white Toyota taxi cab (Plate No. PVD-115) driven by Petrus.
Victim was rendered unconscious by a sleeping substance, then handcuffed and chained inside a house owned by Susana in Camilla Sorrento Homes, Bacoor, Cavite, where he was detained for 22 days.
Ransom demands of US$600,000 plus Php20,000 per day were made for his release. He was rescued on February 11, 2004, by Philippine National Police PACER operatives.

Onglingswam hailed the taxi from Makati Shangrila Hotel to Virra Mall, San Juan, and while in the taxi near SM Megamall, he received a phone call. Petrus, the driver, repeatedly looked at him during the call.
Onglingswam subsequently lost consciousness and awoke handcuffed and chained with a plastic bag over his head.
A masked man identifying himself as “John” (Petrus) informed him of the kidnapping.
Victim was allowed to make monitored calls to family and girlfriend to arrange ransom without disclosing kidnapping initially.
Family was informed and made ransom payments via bank deposits. Victim was maltreated during captivity (beaten, forced to bite wood targets).
Police traced and arrested Petrus on February 11, 2004, along Aguinaldo Highway with the taxi.
Petrus led police to the victim inside the house where he was detained.
DNA tests matched Petrus with the mask used in the kidnapping.

Petrus denied involvement, claiming a frame-up conspiracy coordinated by the victim and police.
Petrus stated he was at home sleeping on the date of the supposed kidnapping.
Alleged that he was later forcibly abducted, beaten unconscious, and detained by unknown persons.
He clarified his taxi was bought for personal use, not for earning, and had a defective engine.
Petrus and Susana had been separated since June 2003; Susana lived elsewhere and denied involvement, claiming she was detained with family after Petrus was arrested.
Susana denied feeding the victim or participating in any way; she also stated she owned three houses, registered in her name.

RTC found Petrus guilty as principal for kidnapping for ransom and serious illegal detention.
Susana was found guilty as an accomplice for providing moral and material support.
Testimonies of prosecution witnesses were credible, including positive identification of Petrus by victim and family.
Circumstantial evidence and DNA results corroborated charges.
Alibi and frame-up defenses were rejected for lack of clear and convincing evidence.
Petrus sentenced to reclusion perpetua; Susana sentenced under the Indeterminate Sentence Law as an accomplice.
Both ordered to pay actual, moral, and exemplary damages jointly and severally.

Affirmed RTC convictions, sustaining credibility of prosecution witnesses and sufficiency of evidence.

Petrus and Susana appealed and raised issues on illegal arrest, lack of positive identification, and innocence.
The Supreme Court allowed supplemental briefs; the OSG maintained its positions.

Whether the accused-appellants were illegally arrested, thereby affecting the admissibility of seized evidence.
Whether there was positive identification of Petrus Yau as the kidnapper beyond reasonable doubt.
Whether the prosecution sufficiently proved the crime of kidnapping for ransom and the accused’s guilt beyond reasonable doubt.
Whether Susana Yau’s conviction as an accomplice is supported by evidence.
Proper apportionment and reasonableness of damages awarded.
Whether the defenses of alibi and frame-up raised by the accused-appellants ought to be given credence.