Title
People vs. Sam
Case
G.R. No. L-4287
Decision Date
Dec 29, 1953
Chan Teng, a Chinese businessman, was kidnapped for ransom in 1950 by individuals posing as police officers, later found dead. Thirteen were charged; eight convicted, with three sentenced to death and others to life imprisonment. Lee Tao was acquitted due to insufficient evidence.

Case Summary (G.R. No. 146641-43)

Charges and Court Proceedings

The accused were charged in the Court of First Instance of Manila with kidnapping Chan Teng for ransom and causing his death through treachery. Of thirteen defendants, eight were tried and found guilty. The trial concluded with the imposition of capital punishment, alongside a P5,000 indemnity for the heirs of the deceased, prompting an appeal from the convicted individuals.

Evidence for the Prosecution

The prosecution established that Chan Teng was kidnapped by Gonzales and Reyes under the pretense of being taken to Camp Crame for alleged communist activities. After being forced into a car driven by Apolinario Pelaez, he was taken to a house in Pasay, where he was tied up and held captive. Teng attempted to escape but was caught and severely beaten. He was later transferred to another location, where his lifeless body was discovered, indicating violent abuse and leading to conclusion of foul play in his death due to intracranial hemorrhage.

Circumstantial Evidence and Notes

The prosecution highlighted two notes found during the investigation—one from Chan Teng requesting ransom and another indicating his location—but emphasized that several defendants' actions following the kidnapping demonstrated a coordinated effort to conceal the crime. After the discovery of Teng's corpse, many defendants fled, a fact suggesting awareness of their implicating involvement. Evidence gathered included witness testimonies and confessions from some accused, despite claims that these were coerced.

Defense Arguments

The defense did not completely deny participation but claimed ignorance of the kidnapping's purpose, suggesting that the real masterminds were those still at large. Testimonies by several accused essentially attempted to distance themselves from the crime, alleging they were misled or merely used by others in the scheme.

Court’s Findings on Credibility

The trial court weighed the testimonies and evidence, ultimately favoring the prosecution's narrative. The defendants' explanations often lacked credibility and were inconsistent with the evidence. Their attempts to shift blame were viewed as self-serving, diminishing their reliability in disassociating from the conspiracy.

Conspiracy Findings

Regarding conspiracy, the court determined that an agreement to commit the crime was implied from the actions and collaboration of the defendants, fulfilling the legal standard for conspiracy under the Revised Penal Code. The court highlighted the intertwined roles played by the defendants, illustrating a collective objective centered on kidnapping and e

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