G.R. No. 248456 - People vs. Dela Cruz y Resurreccion

Case Summary (G.R. No. 248456)

Key Dates

• August 9–10, 2013 – Kidnapping and release of Elisa; ransom negotiation and payoff
• December 16, 2013 – Filing of Information for Kidnapping for Ransom
• November 17, 2017 – RTC (Branch 92, Calamba) Decision convicting appellants
• March 20, 2019 – CA Decision affirming RTC ruling (CA-G.R. CR-HC No. 10251)
• August 16, 2022 – SC Decision (G.R. No. 248456)

Applicable Law

• 1987 Philippine Constitution
• Revised Penal Code, Article 267 (Kidnapping and Serious Illegal Detention; penalty for ransom cases)
• Republic Act No. 9346 (abolition of death penalty; substitution of reclusion perpetua)
• Rule 110, Section 13, and Rule 120, Section 3, Rules of Court (prohibition against duplicity; judgment on multiple offenses)
• A.M. No. 15-08-02-SC, Item II(2) (use of “without eligibility for parole” when death penalty is commuted)

Factual Antecedents

On August 9, 2013, Jenny Dela Cruz reported the kidnapping of her sister Elisa and brother-in-law Jason to PNP-AKG.
Elisa was released the following morning in Cavite to secure ransom funds. She was brought to Camp Crame, where in the presence of PNP-AKG officers she negotiated for ₱867,000.
During the payoff on SLEX, PNP-AKG operatives tailed Elisa’s vehicle and observed a white Honda Civic (Plate WKV-152) tailing her. At a Shell station, occupants of the Civic alighted, changed seats, and continued pursuit.
Near a Petron station, Elisa dropped the ransom; one passenger—later identified as Viaesa—retrieved the money.
That evening Jason was released. Elisa, Jason, and their helper executed affidavits detailing the incident.
Investigation traced the Civic to Tyrone Dela Cruz via a used-car dealer, confirmed by photographic identification through social media and by police officers who saw Dela Cruz and Viaesa at the Shell station.

Trial Court Ruling (RTC)

• Found appellants guilty beyond reasonable doubt of Kidnapping for Ransom (Art. 267, RPC) based on cumulative circumstantial evidence:
– Initial complaint by Jenny;
– Officers’ presence at Elisa’s release, negotiation, preparation, and monitoring of payoff;
– Positive identification of appellants as Civic passengers and ransom retriever.
• Sentence: Reclusion perpetua (in lieu of death) and joint-and-several awards of ₱867,000 actual damages, ₱75,000 civil indemnity, ₱75,000 moral damages, ₱30,000 exemplary damages, plus 6% interest.

Court of Appeals Ruling

• Affirmed RTC decision in toto.
• Held that circumstantial evidence, as witnessed by PNP-AKG operatives, sufficiently established kidnapping and ransom extortion despite affidavits of desistance by victims.

Issue

Whether the prosecution proved appellants’ guilt beyond reasonable doubt in the absence of direct testimony from the kidnapped spouses.

Supreme Court Ruling and Analysis

The prosecution satisfied all elements of Kidnapping for Ransom under Article 267, RPC:
a. Private individuals deprived victims of liberty;
b. Detention was unlawful;
c. Purpose was ransom extortion.
Circumstantial evidence rule applies: a “mass of circumstances” pointing unerringly to guilt may dispense with direct proof of abduction.
Conspiracy inferred from coordinated acts—tracking Elisa’s vehicle, coordinating passenger movements, jointly retrieving money.
Victims’ absence at trial did not render operative testimonies hearsay: PNP-AKG officers testified from personal knowledge and perception.
Single Information charged one offense for two victims; duplicity rule breached but not timely challenged by motion to quash and thus deemed waived.
Under Section 3, Rule 120, Rules of C

Case Syllabus (G.R. No. 248456)

Facts of the Case

On August 9, 2013, spouses Jason Edward Tay Huang and Elisa Dela Cruz Huang were reported kidnapped in Barangay Pansol, Calamba, Laguna.
The kidnappers demanded a ransom of ₱30,000,000.00, later reduced to ₱867,000.00.
Elisa was released the next day in Cavite to arrange payment; Jason remained in captivity until later that evening.
During the negotiated payoff along the South Luzon Expressway (SLEX), a white Honda Civic (Plate No. WKV-152) trailed Elisa’s vehicle.
A passenger later identified as Sandy Viaesa retrieved the ransom from the ground near a Petron station.

Procedural History

December 16, 2013: Information filed charging Tyrone Dela Cruz y Resurreccion, Jezreel Jimmy Cuevas, Sandy Viaesa, and John Doe with Kidnapping for Ransom under Article 267, RPC.
Arraignment: Dela Cruz and Viaesa pleaded not guilty; Cuevas remained at large and the case against him was archived.
Private complainants executed affidavits of desistance, but the RTC proceeded to trial.
November 17, 2017: RTC Branch 92, Calamba, Laguna rendered a Decision finding the accused-appellants guilty beyond reasonable doubt.
March 20, 2019: Court of Appeals affirmed the RTC Decision in CA-G.R. CR-HC No. 10251.
Supreme Court: Appeal from the CA Decision dated March 20, 2019 under G.R. No. 248456, decided August 16, 2022.

Prosecution’s Evidence

PCI Jeffrey Fallar received the initial kidnapping report from Jenny Dela Cruz on August 9, 2013.
PNP-AKG operatives fetched Elisa at Camp Crame after her release and witnessed her negotiate with the kidnappers via telephone.
Elisa prepared and labeled ransom bills; officers noted serial numbers and tail-gated her car en route to SLEX.
Police observed the white Honda Civic with four occupants stop beside Elisa’s car at a Shell station; occupants changed seats before following.
At the ransom drop-off near a Petron station, PCI Jonel Guadalupe positively saw Viaesa retrieve the money.
Investigation linked the Honda Civic to Dela Cruz through seller Jun Cacanando and corroborated by social media photographs.
Jason and their helper, Albert Serrado, later identified Dela Cruz and Viaesa in photographs.
Barangay Chairman Ariel Barrios of Sibulan, Nagcarlan, Laguna confirme