Case Summary (G.R. No. 140900)
Facts of the Case
The prosecution's evidence indicates that Joseph Co and Linda Manaysay were kidnapped at approximately 1:45 a.m. while supervising food collection from their restaurant branches. They were approached by multiple armed men, forced into their vehicle, and subsequently taken to a safehouse in Daang Bakal, Parang, Marikina, where they were held for ransom. Co and Manaysay managed to escape the following day and alerted the police, which led to the arrest of Licayan and Lara.
Charges and Initial Trial
The accused-appellants were charged with Kidnapping for Ransom under Article 267 of the Revised Penal Code and with robbery. The trial court acquitted them of robbery but found them guilty of kidnapping and sentenced both to death by lethal injection, along with financial penalties in favor of the victims. The prosecution's case heavily relied on the positive identification of the accused by the victims.
Defense by Accused-Appellants
Licayan and Lara asserted an alibi, arguing their whereabouts at the time of the kidnapping and claiming illegal arrest procedures. They contended that their identities were not satisfactorily established and maintained they were mere accomplices rather than the main perpetrators. Both also argued their arrests were unlawful as they claimed the police lacked sufficient circumstantial evidence to justify a warrantless arrest.
Legal Findings on Alibi and Identification
The court noted that the positive identification of the accused by Co and Manaysay was credible. Despite the defense's claims about inconsistencies in the victims' testimonies and concerns about their recollections of the assailants' physical features, the testimonies were consistent on critical points regarding the accused's involvement. The Court emphasized that alibi defenses are generally weak and are not sufficient when incriminating evidence is robust.
Arrest and Custodial Rights
The court determined that the claim of illegal arrest was procedurally barred since the accused entered not guilty pleas without contesting this issue during arraignment. Any irregularities during the arrest were deemed resolved by their voluntary participation in the trial process. Claims regarding lack of counsel during custodial investigation were addressed by affirming that the rights were upheld and validated by a counsel de officio.
Conspiracy and Participation
The claim that the appellants acted merely as accomplices was rejected. The Court found sufficient evidence suggesting their active participation and conspiracy in the kidnap
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Case Overview
- The case involves an automatic review of the Consolidated Decision dated September 9, 1999, by the Regional Trial Court, Branch 272, Marikina City.
- Accused-appellants Roderick Licayan and Roberto Lara were found guilty of Kidnapping for Ransom under Article 267 of the Revised Penal Code and sentenced to death by lethal injection.
- They were ordered to pay moral and exemplary damages amounting to P100,000.00 each, and P20,000.00 for actual damages to private complainant Joseph Co.
- The accused-appellants were acquitted of robbery charges.
Facts of the Case
- The Information for Kidnapping for Ransom indicates that on August 10, 1998, at approximately 1:45 a.m., the accused, armed and in conspiracy, kidnapped Joseph Tomas Co and Linda Manaysay to extort ransom.
- The complainants were taken from Goodies Pares Mami House in Sampaloc, Manila, to a house in Daang Bakal, Parang, Marikina, where they were held captive until escaping on August 11, 1998.
- The Information for Robbery detailed that personal belongings were taken from the complainants during the kidnapping.
Complainants' Routine and Abduction
- Complainant Joseph Tomas Co, owner of Goodies Pares Mami House, regularly inspected his restaurant branches late at night with cashier Linda Manaysay.
- On August 10, after visiting the Sampaloc branch, Co was approached by three armed men who refused to accept money from the store.
- The complainants were forced into their own vehicle, with th