Title
People vs. Puno y Guevarra
Case
G.R. No. 97471
Decision Date
Feb 17, 1993
Accused-appellants, posing as drivers, abducted and extorted money from a bakeshop owner. The Supreme Court ruled the crime as simple robbery, not kidnapping or highway robbery, due to lack of intent to deprive liberty and targeted nature.

Case Summary (G.R. No. 97471)

Procedural Posture

An information filed May 31, 1989 charged the appellants with kidnapping for ransom (Article 267, RPC). After arraignment and trial, the trial court (promulgated September 26, 1990) convicted them of robbery with extortion committed on a highway under P.D. No. 532 and sentenced each to reclusion perpetua, and ordered payment of actual and temperate damages. The appellants appealed, contending (1) they were not charged under P.D. No. 532 and thus could not be convicted thereunder, and (2) the application of Sections 4 and 5, Rule 120 was erroneous because the offense proved was not necessarily included in the charged offense.

Material Facts Found by the Trial Court and Adopted on Appeal

The appellate court adopted the trial court’s factual findings. On January 13, 1988, Isabelo, who worked as the husband’s driver, drove the victim in her employer’s Mercedes. Enrique entered the vehicle, displayed a gun, and, with Isabelo’s participation, compelled the victim at gunpoint to surrender P7,000 in cash and sign three checks (two for P30,000 and one for P40,000) after threatening her and demanding P100,000. The victim was held in the car while the perpetrators drove along highways; she later escaped by jumping from the vehicle on the North Superhighway and reported the incident to authorities. Enrique was later arrested attempting to encash one of the checks.

Trial Court Ruling and Its Rationale

The trial court rejected the kidnapping-for-ransom charge and instead found the appellants guilty under P.D. No. 532 for robbery with extortion committed on a highway, imposing the severe penalty of reclusion perpetua. The trial court relied on the fact that the robbery occurred while the victim was carried from one place to another on thoroughfares and that the perpetrators extorted additional money en route.

Issues Raised on Appeal

Primary issues addressed by the appellate court: (1) whether the evidence established kidnapping for ransom or another offense; (2) whether the crime constituted “highway robbery/brigandage” punishable under P.D. No. 532; and (3) whether simple robbery is a necessarily included offense in the information charging kidnapping for ransom, allowing conviction under the lesser included offense doctrine (Sections 4 and 5, Rule 120).

Parties’ Contentions on Appeal

Appellants argued they were improperly convicted under P.D. No. 532 because the information charged kidnapping for ransom, not highway robbery, and that Section 4 and 5, Rule 120 could not be used to convict for an offense not proven as necessarily included. The Solicitor General and the trial court maintained that the conduct fell within P.D. No. 532 and that the decree modified applicable provisions of the Revised Penal Code.

Legal Standards Applied: Kidnapping for Ransom and Robbery

The court reiterated that kidnapping for ransom and serious illegal detention require proof of an actual intent to deprive a person of liberty. Established jurisprudence holds that detention or asportation incidentally attendant to the commission of another primary offense does not of itself constitute kidnapping when the primary intent was robbery or another crime. Robbery under Article 293 was characterized as unlawful taking with intent to gain by means of intimidation. Ransom was defined as payment demanded for the redemption of a captured person—i.e., payment that releases from captivity.

Court’s Analysis on Motive, Specific Intent, and Kidnapping

The appellate court found no evidence that the appellants nurtured any motive to deprive the victim of her liberty other than to extort money. Appellant Puno’s testimony, conceding that money and checks were obtained early in the episode and that the victim’s further detention was not an end in itself but a tactical measure, reinforced the court’s conclusion that there was no intent to effectuate a ransom-style deprivation of liberty. The deprivation of freedom was thus incidental to the primary objective—robbery by intimidation—and did not satisfy the specific intent element for kidnapping for ransom.

Ransom Element and Immediate Obtention of Money

Because the cash and checks were obtained directly and immediately from the victim under threat, the court held these transfers to be involuntary surrenders incident to robbery, not ransom in the technical sense used in kidnapping law. The immediacy and personal delivery of the money/cheques distinguished the conduct from the classical notion of ransom as payment for release from captivity.

Scope and Purpose of P.D. No. 532 (Highway Robbery/Brigandage)

The court examined P.D. No. 532’s history and scope and concluded that the decree primarily amended the law on brigandage (Articles 306–307, RPC) and targeted indiscriminate highway depredations by roving bands—i.e., crimes against all travelers, not singular targeted robberies against predetermined victims. The preambular language of P.D. No. 532, its use of the terms “highway robbery/brigandage,” and its contemporaneous background support this interpretation. The court emphasized that brigandage addresses bands organized to prey indiscriminately on travelers, whereas a single robbery against a specifically chosen victim does not embody the communal and indiscriminate danger that P.D. No. 532 was enacted to punish.

Statutory Construction and Avoidance of Absurd Results

Applying principles of statutory construction and contemporaneous exposition, the court rejected a literalist approach that would apply P.D. No. 532 merely because the robbery occurred while the vehicle was on a highway. The court warned such an interpretation would yield absurd consequences and conflict with other statutes (e.g., Anti-Carnapping Act, Anti-Cattle Rustling Law) by supplanting specialized crimes and penalties with the broad reach of P.D. No. 532. The legislature’s (and executive promulgator’s) intent was read to preserve the distinctiveness of brigandage/highway robbery as crimes against the traveling public rather than singular targeted robberies.

Application of Included-Offense Doctrine and Rule 120

The appellate court found no procedural obstacle to

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