Case Summary (G.R. No. 209527)
Charge and Plea
Franco de Guzman was charged with kidnapping and serious illegal detention under Article 267 of the Revised Penal Code. The incidents leading to the charges occurred on October 6, 2010, where AAA was allegedly kidnapped and detained for eight days. Upon arraignment, De Guzman pleaded not guilty.
Prosecution's Version of Events
The prosecution's case rested on the testimonies of AAA, his father BBB, his brother CCC, and police officers involved in the arrest. AAA testified that De Guzman had sought his assistance, claiming that his belongings were lost and that he needed to withdraw money from a bank. Under the pretext of needing assistance, De Guzman coaxed AAA to accompany him from Makati to a decrepit house in Antipolo. While there, AAA was detained from October 6 to October 14, where Del Guzman allegedly used threats and intimidation to prevent AAA from escaping, claiming he had bodyguards watching him. AAA was also coerced into performing acts dictated by the appellant, which included sustaining him financially.
Defense's Version
In his defense, De Guzman denied the allegations of kidnapping and serious illegal detention. He provided an alternative narrative, stating that he had met AAA in 2009 and had developed a friendship with him. De Guzman claimed he went to Metro Manila out of personal necessity, specifically to address the loss of belongings. He asserted that AAA willingly accompanied him and denied any intentions of holding him against his will. Furthermore, he emphasized that the household had broken locks, and AAA had the opportunity to leave.
Regional Trial Court's Findings
The Regional Trial Court found De Guzman guilty of the charges, emphasizing the credibility of AAA's testimony, supported by corroborative accounts from his family and law enforcement officers. The RTC ruled that the fear instilled by De Guzman, along with the victim's lack of freedom during the detention, constituted both kidnapping and serious illegal detention as per the requirements of Article 267 of the Revised Penal Code. De Guzman was sentenced to reclusion perpetua without eligibility for parole and ordered to pay moral and exemplary damages to AAA.
Court of Appeals Decision
The Court of Appeals affirmed the RTC's decision, rejecting the appellant's claims that the prosecution failed to establish the crime beyond reasonable doubt. The CA upheld the lower court's findings regarding the credibility of witnesses, maintaining that the inconsistencies in AAA's testimony did not undermine the overall veracity of his claims. The appellate court reaffirmed the conclusions drawn concerning the severity of De Guzman's actions.
Supreme Court’s Final Ruling
Upon review, the Supreme Court dismissed De Guzman's appeal, reaffirming his conviction for kidnapping and serious illegal detention as defined under Article 267 of the Revised Penal Code. The Court emphasized that the actual deprivation of liberty was evident in AAA's experience, which was further substantiated by his fear induced by De Guzman. The appellate court's non-interference with the RTC's cred
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Case Overview
- This case involves an appeal by Franco Darmo de Guzman y Yanzon, also known as Darmo Yazon y Cortez, against the conviction of kidnapping and serious illegal detention.
- The appeal follows a January 21, 2014 Decision by the Court of Appeals affirming the September 4, 2012 Decision of the Regional Trial Court (RTC), Branch 140, Makati City.
- The RTC found the appellant guilty beyond reasonable doubt of the crime as defined under Article 267 of the Revised Penal Code.
Background Information
- An Information was filed on October 28, 2010, charging the appellant with kidnapping and serious illegal detention of a minor, AAA, who was 17 years old at the time of the incident.
- The charge stemmed from events that occurred on October 6, 2010, in Makati City, where the appellant allegedly kidnapped and detained AAA for eight days.
Prosecution's Version
The prosecution presented several witnesses: the victim AAA, his father BBB, his brother CCC, and arresting officers Rufino B. Almodiel, Jr. and PO1 Ger Aaron Sembrano.
Initial Encounter:
- On October 1, 2010, the appellant met AAA in Isetann Mall, Recto, Manila, claiming his belongings were stolen and requesting AAA's help.
- With permission from AAA’s mother, the appellant stayed at their home until October 6, 2010.
Events of October 6, 2010:
- The appellant, AAA, CCC, and a friend named Vincent went to Citibank, Paseo de Roxas, Makati.
- The appellant was unable to withdraw money due to lack of identification and suggested going to Antipolo to open a vault, enticing AAA to accompany him.
- AAA was taken to an old house in Cogeo, Antipolo, where he was detained from October 6 to Octobe