Case Summary (G.R. No. 177526)
Procedural History
The Department of Justice filed an Information on October 15, 1999, against Vicente, Devincio, and four other individuals for kidnapping under Article 267 of the Revised Penal Code. The RTC, in its decision rendered on March 24, 2003, found Vicente and Devincio guilty beyond reasonable doubt and sentenced them to death. This conviction was appealed to the Court of Appeals, which modified the penalty to reclusion perpetua without the possibility of parole, affirming their guilt.
Background of the Crime
The prosecution’s case hinged on the testimony of complainant Nicassius Cordero, who provided a detailed account of his abduction on April 20, 1999. Cordero testified that he was forcibly taken by three armed men, including Devincio Guerrero, to extort ransom from his family. Cordero was held captive for four days, during which threatening demands for ransom were made. Ultimately, Cordero was released without ransom being paid.
RTC Findings
The RTC found Cordero's testimony credible and supported by evidence, including the identification of the accused as his abductors. It emphasized the reliability of Cordero’s identification and described his account as thorough and believable. Consequently, the court held Vicente and Devincio guilty as charged due to compelling proof of their involvement.
Court of Appeals Ruling
On January 23, 2013, the Court of Appeals upheld the RTC's decision but amended the penalty to reclusion perpetua in accordance with Republic Act No. 9346, which prohibits the death penalty. The appellate court affirmed the reliability of Cordero’s identification and rejected Devincio’s arguments about suggestiveness in identification and the legality of his arrest for failing to raise such issues at trial.
Legal Principles
To sustain a conviction for kidnapping for ransom under Article 267, the prosecution must prove four elements: (1) the accused is a private individual; (2) they kidnapped or unlawfully detained the victim; (3) the act of kidnapping or detention was illegal; and (4) the victim was taken for ransom. The Court found that all these elements were satisfied through Cordero’s testimony.
Identification of the Accused
The Court addressed arguments regarding the reliability of Cordero's identification of the accused. It highlighted that sufficient circumstances existed during the initial identification, and discrepancies raised by the defense regarding suggestiveness were not substantiated adequately. Cordero positively identified both accused in and out of court, demonstrating the strength of his testimony.
Arguments on Arrest and Rights Violations
Devincio argued that his warrantless arrest was illegal and that his rights under Republic Act No. 7438 were violated. The Court of Appeals rejected these arguments, stating that no objection regarding the legality of his arrest was raised before trial or during his arraignment, the
...continue readingCase Syllabus (G.R. No. 177526)
Overview of the Case
- The case involves an appeal by Vicente Lugnasin and Devincio Guerrero against the decision of the Court of Appeals, affirming their conviction for kidnapping for ransom.
- The original conviction was made by the Regional Trial Court (RTC) of Quezon City.
- The case number is G.R. No. 208404, with the decision rendered on February 24, 2016.
Background of the Case
- The Department of Justice filed an Information against the accused-appellants and several others on October 15, 1999, for kidnapping for ransom as defined in Article 267 of the Revised Penal Code.
- The abduction occurred on April 20, 1999, targeting Nicassius Cordero, who was taken from his residence in Quezon City.
- The accused-appellants were identified by Cordero as involved in the kidnapping, along with other co-conspirators.
Factual Context
- Nicassius Cordero testified that he was abducted by armed men while opening his garage door.
- He identified Devincio Guerrero as one of the men who threatened him with a firearm.
- Cordero was held captive for four days, during which ransom negotiations occurred.
- Ultimately, he was released without ransom being paid.
Procedural History
- Vicente Lugnasin and Devincio Guerrero pleaded not guilty during their respective arraignments.
- The RTC found them guilty beyond reasonable doubt and sentenced them to death, later modified by the Court of Appeals to reclusion perpetua without parole.
Ruling of the RTC
- The RTC determined that Co