Case Summary (G.R. No. 250980)
Applicable Law and Legal Framework
The case was adjudicated under the 1987 Philippine Constitution since the decision dates from 2013 to 2022. The crime charged—Kidnapping for Ransom—is codified under Article 267 of the Revised Penal Code. Procedural aspects considered include Rule 117 and Rule 122 of the Rules on Criminal Procedure, and relevant constitutional provisions such as Section 14(2), Article III (Bill of Rights) guaranteeing the right of the accused to be informed of the nature and cause of accusation and to have a speedy, impartial, and public trial. The case also involved the interpretation of Article 89 of the RPC regarding the extinguishment of criminal and civil liabilities by the death of the accused pending appeal.
Charges and Plea
The Amended Information charged all accused with the kidnapping of the three children and Cuevas, demanding ransom in exchange for their release. The accused, with their counsel, entered pleas of "not guilty" at arraignment, except Rey Alada, whose arraignment was not established in the records. At pre-trial, the defense admitted identity, jurisdiction, and ages of the minor victims but maintained their plea.
Trial Court's Decision
On March 26, 2013, the Regional Trial Court Branch 225 of Quezon City found all accused, except Navanes (whose liability was extinguished due to death after arraignment but before judgment), guilty beyond reasonable doubt of kidnapping for ransom. The accused were sentenced to suffer reclusion perpetua (life imprisonment) and ordered to pay moral and exemplary damages amounting to P30,000 each, with legal interest.
Court of Appeals' Resolution
The Court of Appeals (CA), in its June 7, 2019 decision, affirmed the convictions of Rogelio Caloring, Benjamin Olidan y Erlandez, and PO1 Jose Lonmar Zapatos y Fiel. The CA modified the damages, increasing moral damages, exemplary damages, and civil indemnity to P100,000 each, plus six percent interest per annum from finality of judgment until paid. Appeals by other accused were dismissed or withdrawn, leaving only the appeal of Rogelio Caloring for resolution.
Death of the Accused-Appellant and Its Effects
It was established that accused-appellant Rogelio Caloring died on March 10, 2021, during the pendency of his appeal before the Supreme Court. Pursuant to Article 89, paragraph 1 of the RPC, his death extinguished both his criminal and civil liabilities arising from the case due to the lack of a final judgment. The Court emphasized the ruling in People v. Bayotas, which held that death pending appeal terminates criminal liability and any directly related civil liability ex delicto in senso strictiore, while civil claims based on other sources such as contracts or quasi-delicts may survive separately. Accordingly, the Court dismissed the case against Caloring.
Defect in the Information and Waiver of Objection
The Information charged one consolidated offense of kidnapping for ransom involving four victims, effectively alleging four separate counts. The proper procedure requires filing separate Informations for each count/offense, to prevent prejudicing the accused's right to defend themselves by causing confusion. Although the Information was defective for charging multiple offenses in one, the accused waived this defect by failing to move for its quashal before pleading. The Court affirmed this principle as articulated in People v. Jugueta, emphasizing that failure to timely raise the objection constitutes waiver.
Arraignment and Conviction of Rey Alada
Records did not show that accused Rey Alada was ever formally arraigned. He also remained at large throughout the trial despite the issuance of an arrest warrant. The Court underscored that arraignment is indispensable for informing the accused of the charges and securing his constitutional right to due process. Trial in absentia is only allowed after arraignment upon due notice and unjustified absence. Since Alada was not ar
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Case Syllabus (G.R. No. 250980)
Case Background and Parties Involved
- The case involves an appeal by Rogelio Caloring (accused-appellant) from the June 7, 2019 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 06209.
- The CA affirmed with modification the decision of the Regional Trial Court (RTC), Branch 225, Quezon City dated March 26, 2013.
- The RTC found Rogelio Caloring and several co-accused, including Crispin Araneta, Lynfer Bicodo, Annabelle Olidan, Benjamin Olidan, Godofredo Navanes, Rey Alada, PO1 Jose Lonmar Zapatos, and PO1 Antonio Castillo, guilty beyond reasonable doubt of Kidnapping for Ransom under Article 267 of the Revised Penal Code (RPC).
- The modification by the CA pertained to the monetary awards imposed on the accused.
Offense Charged and Information Filed
- The accused were charged in one Information with conspiring to kidnap four victims: the Sermonia children (Vinz, Klevwelt, Genritz, aged 11, 11, and 9, respectively) and Eulalia Cuevas.
- The allegations involved kidnapping for ransom with the use of firearms on or about August 30, 2005, in Filinvest II, Quezon City.
- All accused, except Rey Alada, were arraigned and pleaded not guilty.
- The Amended Information was later found to be defective for charging multiple counts of kidnapping in a single Information.
Trial Proceedings and RTC Decision
- At pre-trial, the defense admitted the identity of the accused, jurisdiction of the court, and minority of three child victims.
- The RTC found all accused except Navanes guilty beyond reasonable doubt.
- Navanes' liability was extinguished due to his death post-arraignment but prior to judgment promulgation.
- The RTC sentenced the convicted accused to reclusion perpetua.
- Civil liabilities were imposed solidarily on the accused for moral and exemplary damages amounting to Php 30,000 each per victim, plus legal interest and costs.
Court of Appeals Ruling
- The CA dismissed the appeals of Araneta and Annabelle and noted Bicodo’s withdrawal of appeal.
- The CA affirmed the convictions of accused-appellant Rogelio Caloring, Benjamin Olidan, and PO1 Zapatos.
- The CA modified the damages awarded: each victim was granted Php 100,000.00 as civil indemnity, moral damages, and exemplary damages, with 6% annual interest from judgment finality.
- The CA maintained reclusion perpetua sentences for the convicted accused.
Accused-Appellant’s Death and Effects on Liability
- Accused-appe