Case Summary (G.R. No. 224562)
Antecedents of the Case
On August 12, 2008, an Information for Kidnapping was filed against Excel. The prosecution later filed an Amended Information to include Wennie and Joel as co-accused. A Second Amended Information was filed on January 6, 2009, alleging the death of the victim, which amended the charge to Kidnapping with Homicide, specifying that the accused unlawfully kidnapped AAA for ransom and subsequently murdered her.
Trial and Key Testimonies
During the trial, evidence was presented indicating that AAA was last seen with Wennie before her disappearance. Messages demanding ransom were sent to AAA's family, indicating that she was in the custody of the kidnappers. The prosecution highlighted suspicious conduct by Wennie, such as deleting texts from Patrick’s phone and misdirecting inquiries about Joel, further implicating her in the conspiracy to commit the crime. Joel pleaded guilty to the charges and alleged that Wennie had no involvement, while claiming Excel assisted only in receiving ransom money.
Ruling of the Regional Trial Court (RTC)
The RTC convicted Wennie and Joel as principals and Excel as an accomplice for Kidnapping with Homicide on December 5, 2012. The court sentenced Joel and Wennie to reclusion perpetua and imposed an indeterminate sentence on Excel, requiring him to serve 8 years and 1 day of prision mayor.
Ruling of the Court of Appeals (CA)
The CA affirmed the RTC’s verdict on September 23, 2015, concluding that sufficient evidence established a conspiracy between Wennie and Joel. The CA modified the damages awarded, increasing civil indemnity and adding moral and exemplary damages, while allocating a share of the liability among the accused based on their roles in the crime.
The Main Issue
The primary issue for resolution was whether the prosecution sufficiently proved the guilt of Wennie and Excel beyond a reasonable doubt. Both accused claimed the prosecution failed to establish their involvement, particularly disputing the sufficiency of circumstantial evidence linking them to the crime.
Court’s Ruling on the Guilt of Wennie
The Court affirmed that the prosecution firmly established Wenni’s role as a principal in the conspiracy to kidnap AAA, noting several suspicious actions she undertook that corroborated her guilt. The Court emphasized that conspiracy could be inferred from the collective actions of the accused, and thus, both Joel and Wennie were held jointly liable for the criminal acts resulting from the conspiracy.
Court’s Ruling on Excel’s Guilt
In regard to Excel, the Court found that while he was involved in the aftermath of the crime by facilitating the transfer of ransom funds, he did not directly participate in the kidnapping act itself. The Court determined that the evidence presented did not meet the threshold of proving him as an accomplice to the kidnapping, indicating his involvement was limited to actions after th
...continue readingCase Syllabus (G.R. No. 224562)
Case Summary
- The case involves Excel Gurro y Maga (Excel) and Wennie Idian y Jamindang (Wennie) as petitioners, and the People of the Philippines as the respondent, in a matter concerning their conviction for Kidnapping with Homicide.
- The main issue revolves around whether the prosecution sufficiently established the guilt of Wennie and Excel beyond a reasonable doubt.
- The decision, dated September 23, 2015, and the subsequent resolution on May 11, 2016, by the Court of Appeals affirmed the conviction by the Regional Trial Court (RTC) of Marikina City.
Antecedents
- On August 12, 2008, an Information for Kidnapping for Ransom was filed against Excel.
- The prosecution later amended the Information to include Wennie and Joel Jamindang y Zosa (Joel) as additional accused, and subsequently to Kidnapping with Homicide upon the victim's death.
- The accused were charged with conspiring to kidnap an 8-year-old girl (AAA) for ransom, demanding Php 3,000,000.00 but only receiving Php 186,000.00.
- AAA was reported missing after being seen with Wennie, and the family received ransom demands via text messages.
- Joel pleaded guilty, while Excel and Wennie pleaded not guilty during the trial.
Factual Background
- Prosecution witnesses, including Patrick Mabulac, testified that they saw AAA at Wennie's house on August 2, 2008, before her disappearance.
- The victim was later confirmed to have been murdered while in the accused's detention.
- Evidence was presented showing Wennie's suspicious actions, including deleting contacts and messages from Patrick