G.R. No. 264958 - People vs. Jonnel Delos Reyes y Tungol

The accused, Jonnel Delos Reyes y Tungol, was charged with serious illegal detention under Article 267 of the Revised Penal Code, as amended by Republic Act No. 7659.
The incident involved the detention and subsequent detention-related abuse of a 15-year-old minor, identified as AAA264958, in xxxxxxxxxxx, Bataan, Philippines, during the period from October 23 to October 25, 2014.
The prosecution also invoked provisions of Republic Act No. 7610 concerning the protection of children against abuse, exploitation, and discrimination.

The case was raffled to the Regional Trial Court, Branch 94, in xxxxxxxxxxx, Bataan, where Delos Reyes pleaded not guilty.
The trial went forward with the prosecution presenting testimonies from the private complainant AAA264958, as well as from Ciara Sumera, Miriam Sanchez, and Police Officer III Darwin Ortega.
The defense presented Delos Reyes as its sole witness, offering a different account of the events.

AAA264958 testified that on October 23, 2014, he accompanied Delos Reyes to collect money as part of his initiation into the Triskellion Fraternity.
After engaging in a drinking session, when Sherlyn (the expected contact) did not appear by 5:30 p.m., AAA264958 asked to leave. Instead, Delos Reyes pointed a knife at him, tied his hands with a nylon cord, and blindfolded him with cloth pieces.
Delos Reyes then led the complainant to the nearby fraternity camp and forced him to take steps until, on his fourth step, he was pushed into an approximately 20-foot deep open pit.
The complainant managed to free himself two days later on October 25, 2014, after which he sought help and reported the incident to local authorities.

Delos Reyes testified that on October 24, 2014, AAA264958 visited his house during his lunch, and subsequently they sought permission from his father to travel to Bataan.
According to the defense, upon arriving, AAA264958 met his friends who were swimming, and later, around 4:30 p.m., Delos Reyes inquired if it was time to return home.
On October 25, 2014, AAA264958 was reportedly apprehended at his house by police officers who handcuffed and arrested him without explanation, after which he was taken to the police station.

By Decision dated May 22, 2019, the trial court convicted Delos Reyes of serious illegal detention.
He was sentenced to reclusion perpetua, together with accessory penalties and costs.

The appellate court affirmed the trial court’s conviction.
Additionally, the Court of Appeals awarded civil indemnity, moral damages, and exemplary damages of PHP 75,000.00 each, ordering an interest rate of 6% per annum on the awarded amounts.

Article 267 of the Revised Penal Code, as amended by Republic Act No. 7659, defines the crime of serious illegal detention and prescribes the corresponding penalties.
The elements of the crime include:

The offender being a private individual acting without legal authority.
The act of kidnapping or detaining another, thereby depriving the victim of his liberty.
The presence of aggravating circumstances such as the detention lasting more than five days, use of simulated public authority, infliction of serious physical injuries, or for detaining a minor.

Article 63 of the Revised Penal Code guides the application of penalties when two indivisible penalties are prescribed.

Whether the testimony of the private complainant AAA264958 was clear, straightforward, and convincing enough to establish all elements of the crime.
The significance of alleged discrepancies, such as the absence of reported injuries in the medical certificate, in negating the complainant’s account.

Confirmation that the act committed by Delos Reyes – tying the complainant, blindfolding him, and pushing him into a deep pit – constitutes a deliberate and unlawful deprivation of liberty.
Whether the fact that the victim was a 15-year-old minor automatically satisfies one of the aggravating circumstances under Article 267.

Whether the conviction under Article 267 of the Revised Penal Code is justified in view of the established elements of the crime.
The propriety of imposing reclusion perpetua based on the rule that, in the absence of mitigating or aggravating circumstances, the lesser penalty in cases where two are provided shall be applied.

Whether the imposition of liquidated damages (PHP 75,000.00 each for civil indemnity, moral damages, and exemplary damages) complies with precedents and statutory mandates in similar cases.