Title
People vs. Larranaga
Case
G.R. No. 138874-75
Decision Date
Feb 3, 2004
Gruesome 1997 kidnapping, gang-rape, and murder of Marijoy Chiong; sister Jacqueline remains missing. Accused convicted based on credible witness testimony, alibi defense rejected.

Case Summary (G.R. No. 138874-75)

Petitioner and Respondent

Petitioner/Appellee in the appeal context: People of the Philippines. Respondents/Appellants: the individuals named above who were originally charged with kidnapping and serious illegal detention (two Informations), and who appealed the trial court’s convictions and penalties.

Key Dates

Crimes committed: night of July 16, 1997 (with discovery of Marijoy’s body July 18–19, 1997). Fourth Amended Informations filed: May 12, 1998. Trial court decision (Regional Trial Court, Branch 7, Cebu City): May 5, 1999 (conviction). Decision on appeal by the Supreme Court: February 3, 2004 (basis: 1987 Constitution, as post-1990 decision).

Applicable Law and Procedural Rules

Constitutional baseline: 1987 Philippine Constitution, Article III (due process, right to counsel, presumption of innocence, confrontation). Relevant rules cited: Rule 115 Revised Rules of Criminal Procedure (rights at trial), Rule 119 Sec. 9 (discharge of accused to be state witness), Sections 8–9 Rule 110 (designation of offense and cause of accusation). Substantive statute: Article 267, Revised Penal Code as amended by R.A. No. 7659 (kidnapping and serious illegal detention; last paragraph creating special complex crime when victim dies, is raped, or subjected to dehumanizing acts). Other procedural and penal provisions (e.g., Article 48, Article 68, Indeterminate Sentence Law) applied as in the decision.

Informations and Charges

Two separate Criminal Cases: (1) CBU-45303 charging kidnapping and related rape and homicide of Marijoy Chiong (alleging carnal knowledge against her will, physical injuries, throwing into ravine causing death); (2) CBU-45304 charging kidnapping and serious illegal detention of Jacqueline Chiong (detained and still missing). The Fourth Amended Informations included all appellants; Rusia was initially an accused and later offered as a state witness.

Summary of Prosecution Case and Main Witness (Rusia)

Primary prosecution witness: Davidson Rusia, who confessed to participation and testified in detail regarding the sequence from encounter at Ayala Center, forcible abduction into a white car, handcuffing and tape, retention at a Guadalupe safehouse, transport by van to Tan-awan, repeated rapes of both victims by various participants, and the pushing of Marijoy into a ~150-meter ravine. Rusia’s testimony was corroborated in material respects by 21 other witnesses who saw parts of the events (observations at Ayala Center, pursuit, white van presence near cliff, identification at Tan-awan, and forensic identification of the corpse).

Corroborative and Physical Evidence

Multiple independent witnesses corroborated key segments of Rusia’s account (e.g., Sheila Singson, Analie Konahap, Williard Redobles saw initial approach; Roland Dacillo and Mario Miñoza observed escape attempts; Manuel Camingao noted presence of a white van at the cliff; fingerprint expert matched corpse prints to Marijoy). Physical evidence on the corpse (handcuff on left wrist, tape over mouth, torn clothing) matched details recounted by Rusia and the family identification.

Defense Case—Alibi and Other Testimony

Primary defenses: denial and alibi. Larrañaga asserted he was in Quezon City taking mid-term examinations at the Center for Culinary Arts and celebrating at an R & R Bar until early morning; numerous witnesses (classmate, teacher, friends, condominium security) testified to his presence in Manila/Quezon City. James Anthony and James Andrew Uy presented testimony that they were at home for their father’s 50th birthday. Alberto and Ariel presented witnesses alleging the white van (plate GGC-491) was at a repair shop during the relevant hours. Many defense witnesses were relatives or friends, and several contradictions and inconsistencies affected their credibility.

Procedural Issues on Appeal—Overview of Assignments of Error

Appellants’ principal contentions on appeal consolidated into four main themes: (1) violation of due process (denial of counsel of choice, rushed trial, inability to present evidence); (2) improper discharge of Rusia from accused to state witness under Rule 119; (3) insufficiency and unreliability of prosecution evidence (primarily Rusia); and (4) trial court bias and prejudicial conduct (judge’s comments, alleged limitation on defense presentation and cross-examination).

Due Process Analysis—Right to Counsel and Continuance

The Court analyzed appellants’ due process claims under the 1987 Constitution and Rule 115. The trial court’s appointment of counsel de oficio was held proper where counsel de parte abruptly withdrew mid-trial, causing dilatory tactics and threatening continuity in a case under mandatory continuous trial. The right to counsel-of-choice is not absolute such that the court must halt proceedings indefinitely until the preferred counsel be available; a continuance request for one month or three weeks was deemed unreasonable. The trial court’s denial of lengthy postponements and its appointment of public defenders did not constitute a violation of due process given the circumstances and the defendants’ capacity to secure counsel in reasonable time.

Due Process Analysis—Right to Confront, Cross-Examination and Waiver

Appellants argued deprivation of confrontation and cross-examination. The records showed multiple lawyers conducted cross-examination of Rusia on several dates; time limits were imposed to prevent waste and repetition given many co-accused and counsel, and such limitation was within the court’s discretion. Where newly retained counsel declined to cross-examine certain witnesses, the trial court treated those witnesses as waived for cross-examination—a valid consequence when counsel opts not to utilize the opportunity. The Court found no denial of the constitutional right to confront witnesses.

Due Process Analysis—Impartiality of the Trial Judge

Allegations of bias based on the trial judge’s interjections, admonitions, and critical remarks were examined. The Court held that judge intervention was proper to focus relevance (e.g., the scope of alibi proof) and preserve efficient proceedings; remarks which chastised or expressed incredulity were viewed as efforts to test credibility and elicit clarification rather than indications of disqualifying bias. Where judge’s questioning aided clarification and allowed redirect, it did not deny an impartial trial.

Admissibility and Exclusion of Defense Evidence

The trial court excluded certain airline personnel testimony and repetitive alibi witnesses as not proving physical impossibility—i.e., showing non-presence in specific flight manifests did not preclude travel on other flights or prior dates, and enrollment records do not disprove temporary travel to Cebu. Exclusion of irrelevant, immaterial or incompetent testimony does not violate due process. The Court sustained the trial court’s rulings as reasonable in the exercise of its discretion.

Discharge of Rusia as State Witness—Rule 119 Considerations

Appellants argued Rusia failed to meet Rule 119 Sec. 9 requirements (e.g., not the least guilty, no prior conviction involving moral turpitude). The Court concluded that even if the trial court erred in discharge determination, such error is not reversible where the discharged witness’s testimony is competent and corroborated by evidence. Rusia’s degree of culpability was assessed as not necessarily the “most guilty” for kidnapping/illegal detention despite admissions of rape; his detailed account, remorse, nightmares, and the strong physical corroboration rendered his testimony credible and admissible as a state witness. The Court also noted that discharge, once effected, has the effect of acquittal and will not be recalled unless the witness refuses to testify.

Assessment of Credibility and Sufficiency of Evidence

The Court afforded deference to the trial court’s credibility assessments based on its superior vantage to observe demeanor. Rusia’s testimony remained steadfast under cross-examination and was corroborated materially by independent witnesses and physical evidence; defense alibi witnesses exhibited contradictions and potential bias. The requirements for alibi—strict demonstration of physical impossibility to commit the crime—were not met. The collective evidence established appellants’ participation and concerted design rather than mere presence.

Legal Characterization—Special Complex Crime under Article 267

Applying Article 267 as amended by R.A. No. 7659, the Court held that where a kidnapped victim is killed, raped, or subjected to dehumanizing acts in the course of detention, the offense constitutes a special complex crime punishable by the maximum penalty. For CBU-45303 (Marijoy), the combination

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