Case Summary (G.R. No. 203961)
Background of the Case
On August 15, 2001, the Supreme Court affirmed the Regional Trial Court (RTC) of Marikina City’s decision convicting Licayan and Lara of kidnapping for ransom, sentencing them to death. The Court modified the RTC ruling by ordering the accused-appellants to pay P50,000.00 each in moral damages but deleting the award of actual damages. Following this, the Court noted that records should be forwarded to the President for possible clemency under R.A. No. 7659.
Events Following Conviction
The Motion for Reconsideration filed by Licayan and Lara was denied on October 9, 2001, and the decision became final on November 9, 2001. A writ of execution was issued by the RTC for January 30, 2004; however, just days before the execution, two co-accused were arrested, prompting the Public Attorney's Office (PAO) to request a reopening of the case to allow for further evidence.
Suspension of Execution
On January 26, 2004, the Court voted to suspend Licayan and Lara's execution for thirty days. Subsequently, on February 17, 2004, the Court granted the PAO's Urgent Motion to Reopen the Case. The case was remanded to the RTC for the reception of additional evidence, while the evidence from the initial trial was preserved.
Second Arraignment and Trial
On April 19, 2005, the RTC arraigned Mabansag and Delos Reyes, who pleaded not guilty. The prosecution charged both with conspiring and kidnapping Co and Manaysay for ransom amounting to P10 million. The prosecution relied on eyewitness testimonies detailing how the complainants were abducted and detained, as well as evidence of the armed confrontation.
Convictions and Appeals
On February 17, 2009, the RTC convicted Licayan, Lara, and Delos Reyes for Kidnapping for Ransom under Article 267 of the Revised Penal Code, sentencing each to reclusion perpetua. They were held liable for P50,000.00 in moral damages to each complainant but were acquitted in a separate robbery charge due to insufficient evidence.
Progression to Higher Courts
The decision from the RTC was upheld by the Court of Appeals on July 4, 2012. Following their appeals, the Supreme Court carefully reconsidered the circumstances surrounding the kidnapping, including the identities of the accused and the reliability of witness testimonies.
Defense and Counterarguments
During retrial proceedings, the accused-appellants presented alleged newly discovered evidence and asserted inconsistent identification by the victims. However, testimonies showed that Co had recognized both Licayan and Lara during their captivity, affirming that their identification was reliable.
Judgment and Penal Consequences
The Supreme Court confi
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Case Overview
- Court: First Division of the Supreme Court of the Philippines
- Case Number: G.R. No. 203961
- Date of Decision: July 29, 2015
- Parties Involved: People of the Philippines (Plaintiff-Appellee) vs. Roderick Licayan, Roberto Lara, and Rogelio "Noel" Delos Reyes (Accused-Appellants)
- Nature of Case: Kidnapping for Ransom
Background of the Case
- Initial Conviction: On August 15, 2001, the Supreme Court affirmed the Regional Trial Court (RTC) of Marikina City's decision convicting Licayan and Lara for Kidnapping for Ransom, sentencing them to death.
- Modification of Decision: The Court modified the judgment, requiring each accused to pay P50,000.00 in moral damages to each complainant, but deleted the award of actual damages.
- Finality of Decision: The decision became final and executory on November 9, 2001.
Execution Proceedings and Developments
- Writ of Execution: Issued on November 18, 2003, for execution on January 30, 2004.
- Reopening of Case: Following the arrest of co-accused Mabansag and Delos Reyes, an Urgent Motion to Reopen the Case was filed on January 15, 2004. The Court suspended the execution for 30 days.
- Granting of Motion: On February 17, 2004, the Court granted the motion to reopen the case and suspended the execution, remanding the records to the lower court for further evidence reception.
Charges and Additional Accused
- Criminal Cases: Two criminal cases were filed against the accused:
- Crim. Case No. 98-2605-MK: Kidnapping for Ransom.
- Crim. Case No. 98-2606-MK: Robbery, for which Licayan, Lara, and Delos Reyes were acquitted due to lack of evidence.