G.R. No. 171653 - People vs. Jatulan y Ponce

The case involves Judith Jatulan y Ponce, who was charged with kidnapping for ransom under Article 267 of the Revised Penal Code.
The incident occurred on February 13, 1995, when Jatulan allegedly kidnapped five-year-old Karwin Amado in Antipolo, Rizal.
The prosecution claimed that Jatulan, along with three co-accused, unlawfully took Karwin to extort a ransom of P250,000 from his family.
The Regional Trial Court (RTC) found Jatulan guilty and sentenced him to death by lethal injection, while acquitting the three minors involved due to insufficient evidence.

During the trial, the prosecution presented testimonies from the victim, his family, and law enforcement officials involved in the investigation.
The defense included testimonies from Jatulan and his co-accused, who denied knowledge of the kidnapping and claimed they were misled by Jatulan.
The RTC ruled in favor of the prosecution, leading to an automatic review by the Court of Appeals (CA) after the conviction.

The CA affirmed the RTC's decision on December 16, 2005, dismissing Jatulan's appeal for lack of merit.
The CA's ruling emphasized the sufficiency of evidence against Jatulan, including the victim's identification and the ransom note delivered to the Amado family.

The prosecution established that Karwin was lured by Jatulan under false pretenses to obtain a toy, leading to his kidnapping.
Testimonies indicated that Karwin was kept in a hut and was not allowed to leave until the ransom was paid.
The ransom note explicitly demanded P250,000 for Karwin's release, corroborating the intent to extort money.

Jatulan's defense claimed that Karwin voluntarily accompanied him and that there was no actual deprivation of liberty.
The defense argued that Karwin could have escaped if he wished, but this was countered by the prosecution's evidence of coercion and manipulation.

Article 267 of the Revised Penal Code outlines the elements of kidnapping, including the requirement that the offender is a private individual and that the act of detention is illegal.
The law specifies that if the victim is a minor, the duration of detention is immaterial, and the crime is punishable by death if committed for ransom.

The Court found that Jatulan's actions constituted kidnapping, as he induced Karwin to leave with him under false pretenses.
The victim's testimony was deemed credible, and the Court rejected Jatulan's claims of innocence, noting the ...continue reading