Title
People vs. Tan
Case
G.R. No. L-2096
Decision Date
Feb 6, 1951
Vicente Po was kidnapped and murdered in 1946; suspects Tan and Tek were convicted based on confessions, witness testimonies, and evidence, with death penalty imposed due to aggravating circumstances.

Case Summary (G.R. No. 173150)

Key Dates

The kidnapping of Vicente Po occurred on December 12, 1946, and he was subsequently killed on December 17, 1946. The case culminated in legal proceedings that resulted in a decision by the court.

Applicable Law

The case involves allegations of kidnapping and serious illegal detention under Article 269 of the Revised Penal Code, as amended by Republic Act No. 18. The trial court sentenced the appellants initially to reclusion perpetua, but the decision was subsequently amended to include the death penalty due to the aggravating circumstances present.

Factual Background

Vicente Po was abducted from 515 Reina Regente Street, Manila, on December 12, 1946. The kidnapping was reported by Jesus Chua, after which Benjamin Calderon and other detectives began the investigation. Ransom notes were subsequently received, leading to intensified police surveillance. On December 16, detectives observed Carlos Miranda Tan arriving at Jesus Chua's home, from which he was later apprehended along with Uy Chen Tek and taxicab driver Nerio Moses. During police questioning, both defendants provided written statements revealing Vicente Po's location.

Evidence Presented

Witness testimonies were crucial to establishing the timeline and events surrounding the kidnapping. Key testimonies came from Calderon, Enriquez (who witnessed the kidnapping), and others who confirmed seeing the defendants with the victim. Tiu's testimony, albeit contradictory, implicated the appellants as participants in the conspiracy. Medical evidence supported claims of torture during their detention, which raised questions about the admissibility of the defendants' extrajudicial statements.

Findings of the Court

The court noted significant discrepancies in Tiu’s testimony but also recognized certain elements of truth within it. Despite Tiu’s inconsistencies, the court found sufficient evidence linking the appellants to the kidnapping. Particularly revealing were acknowledgments from the defendants regarding their presence at crucial junctures during the crime.

Legal Analysis

The court criticized the appellants' defense, which placed the blame on O Pe, the alleged mastermind behind the kidnapping who was deceased. The court found this argument unconvincing given the evidentiary weight against the appellants, particularly regarding their ac

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