Title
People vs. Deduyo
Case
G.R. No. 138456
Decision Date
Oct 23, 2003
Johnny kidnapped for ransom by Deduyo, detained with threats; ransom demanded, Deduyo arrested, trial in absentia; Supreme Court affirmed guilt, modified penalty to death.

Case Summary (G.R. No. 138456)

Case Background

On February 20, 1998, the Regional Trial Court of Antipolo found Rolando Deduyo guilty beyond reasonable doubt of kidnapping for ransom and sentenced him to reclusion perpetua. The information charged that Deduyo, along with MaAago and another still-at-large co-conspirator, kidnapped Johnny Mauricio, demanding ransom for his release.

Plea and Escape

Upon arraignment on June 7, 1994, both Deduyo and MaAago pleaded not guilty. However, Deduyo escaped from jail during a mass jailbreak on July 29, 1994, and was tried in absentia. After his re-arrest, the trial culminated in the February 20, 1998 decision.

Kidnapping Incident Details

On January 30, 1994, Johnny Mauricio was approached by Deduyo, who persuaded him to leave his tricycle to accompany him under the pretense of retrieving a package from the airport. Trusting Deduyo, whom he had known for over a year, Johnny complied. They went to a house where MaAago and another accomplice were present. Johnny was subsequently threatened with a knife and made to stay, leading to his effective confinement in the house, where he feared for his safety.

Ransom Demand

While Johnny was held captive, his mother received a ransom letter demanding P100,000 or at least P50,000, threatening retaliation if she reported the incident to authorities. Under duress, she covertly alerted the police, preparing to meet the ransom demand with only P5,100.

Police Involvement and Capture

On January 31, 1994, while waiting in the church as per the ransom instructions, Johnny's mother encountered MaAago, who inquired about the ransom money. He fled upon being approached by a police officer. Subsequent investigations led to the capture of Deduyo in the act of trying to escape from Pasig, confirming his involvement in the kidnapping.

Trial and Testimony

Johnny’s account of the events was detailed and consistent, highlighting the assault on his liberty through coercion and manipulation, corroborated by testimonies from his mother and law enforcement officers. The defense's attempt to paint Deduyo as innocent was undermined by substantive evidence linking him to the crime, including his flight from justice.

Court's Findings and Conclusion

The trial court found Deduyo guilty based on the overwhelming evidence of his role as the mastermind behind the kidnapping. Key elements of the crime, as defined under Article 267 of the Revised Penal Code, were met: the illegal deprivation of liberty, the threat of violence against Johnny, and the motive for extorting ransom.

Judgment and Penalty Modifications

The conviction was appealed on grounds of perceived innocence; however, the appellate court upheld the trial court's

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