Title
People vs. Yau
Case
G.R. No. 208170
Decision Date
Aug 20, 2014
A lawyer was kidnapped, held for 22 days, and maltreated; the taxi driver was convicted as the principal, and his co-accused as an accomplice, based on DNA evidence and credible testimonies.

Case Summary (G.R. No. 208170)

Key Dates and Procedural Posture

Alleged commission of offense: January 20, 2004 (victim taken unconscious from taxicab). Rescue and arrest: February 11, 2004 (victim found in Bacoor house; Petrus arrested). RTC conviction: December 14, 2007. CA affirmation: September 7, 2012. Supreme Court decision date: August 20, 2014. As the decision date is after 1990, the 1987 Constitution governs relevant constitutional issues in the case.

Applicable Law and Legal Framework

Primary criminal statute invoked: Article 267 of the Revised Penal Code (kidnapping for ransom and serious illegal detention), as amended by Republic Act No. 7659. Other relevant laws and doctrines applied or cited: Article 18 of the Revised Penal Code (liability of accomplices), Article 2219 of the Civil Code (moral damages), Indeterminate Sentence Law, Republic Act No. 9346 (abolition of the death penalty, affecting penalty meted), and pertinent rules on circumstantial evidence and standards of appellate review (trial court’s assessment of witness credibility).

Accusatory Instrument and Nature of Charges

The Information charged Petrus and Susana with kidnapping for ransom in that on or about January 20, 2004, Petrus, with the use of a sleeping substance, allegedly caused Alastair to become unconscious inside a taxi and thereafter detained him, handcuffed and in chains, in the Bacoor house owned by Susana, demanded a ransom of US$600,000.00 and Php20,000.00 per day, and kept him for twenty-two days until his alleged rescue on February 11, 2004. The charge framed kidnapping for ransom and serious illegal detention as the gravamen.

Prosecution’s Version and Evidentiary Highlights

Prosecution evidence described the sequence: victim hailed the white Toyota taxi; while on EDSA near SM Megamall he felt groggy and lost consciousness; upon waking he was handcuffed and chained with a plastic bag over his head; a masked man identifying himself as “John/aJohna” told him he had been kidnapped for ransom and later facilitated communications with family under controlled conditions. The police PACER unit located the taxi (Plate PVD-115) in Bacoor on February 11, 2004, detained the driver who identified the victim as being in his house, led police to the house, and the victim was found handcuffed and chained. Physical and documentary evidence recovered from the house and vehicle included chains and handcuffs, clothing, multiple cellphones and SIM cards, videotapes showing the victim, various documentary items in Susana’s name, Petrus’s driver’s license and cellphones, and a red mask. Forensic evidence included DNA testing showing that DNA from the red mask matched Petrus’s buccal swab. Testimony of the victim and his brother identified Petrus by sight and voice, and recounted ransom demands and communications.

Defense Version and Claims

Petrus and Susana denied the charges and advanced alibi and frame-up defenses. Petrus asserted he was at home sleeping on January 20, 2004, and later related a counter-narrative that he himself was abducted by persons who beat and blindfolded him, resulting in injuries and loss of personal belongings; he claimed the taxi was his personal purchase and not used as a taxi for profit. Petrus also contended that the victim conspired with police to inculpate him. Susana maintained that she was living separately from Petrus since June 2003, had her own residence and business, that she was detained by police for several days after being taken along with her children and helpers, and that many of her personal items were taken by unknown persons.

RTC Judgment and Rationale

The Regional Trial Court (Branch 214, Mandaluyong City) found the prosecution witnesses credible, held that their versions dovetailed and were persuasive, and rejected the defendants’ alibi and frame-up defenses as unsubstantiated. The RTC convicted Petrus as principal of kidnapping for ransom and serious illegal detention and sentenced him to reclusion perpetua (given the application of RA 9346). Susana was convicted as an accomplice and sentenced under the indeterminate sentence framework (minimum taken from the next lower degree), with credit for preventive detention. The trial court also awarded actual, moral and exemplary damages against the accused jointly and severally.

Court of Appeals Disposition

The Court of Appeals affirmed the RTC conviction, agreeing with the trial court’s credibility findings and assessment of the circumstantial and direct evidence identifying the perpetrators and proving the elements of the offense. The CA’s decision formed the basis of the appeal to the Supreme Court.

Issues Raised on Appeal

The accused-appellants assigned errors principally contesting: (1) the legality of their warrantless arrests and the admissibility of seized objects; (2) the asserted lack of positive identification of Petrus as the kidnapper; and (3) the sufficiency of the evidence to sustain conviction. Susana separately raised issues regarding her alleged separate residence, absence from the victim’s affidavit, and the scope of the Department of Justice probable cause finding.

Standard of Review on Witness Credibility

The Supreme Court reiterated settled doctrine that assessments of witness credibility and demeanor are primarily for the trial court, which observed witnesses firsthand. Appellate courts will not lightly overturn such factual findings unless there are overlooked or misapprehended circumstances of weight. The RTC and CA’s credibility determinations thus enjoyed considerable deference.

Application of Circumstantial Evidence Doctrine

The Court applied the established requisites for conviction on circumstantial evidence: presence of multiple circumstances, proof of the underlying facts from which inferences are drawn, and a combination of circumstances that produces conviction beyond reasonable doubt. The Court enumerated and relied upon an unbroken chain of circumstances pointing to Petrus: (1) victim rescued inside house owned by Petrus and Susana; (2) taxi Plate PVD-115 found in Petrus’s possession on February 11, 2004; (3) Petrus’s driver’s license and an ATM card in the name Ong Kwai Ping recovered in the taxi; (4) various items recovered in the house including restraints, videotapes showing the victim, multiple cellphones and documentary evidence linking the house to Susana; (5) cellphones and electronic devices in Petrus’s possession, including a QTEK palmtop linked to another kidnapped victim; and (6) DNA match between the red mask and Petrus. Taken together, these circumstances produced a single reasonable inference that Petrus was the perpetrator.

Elements of Kidnapping for Ransom and Their Establishment

The Court spelled out Article 267 elements applied: (a) intent to deprive liberty; (b) actual deprivation of liberty; and (c) motive of extorting ransom. The Court concluded that these elements were satisfied: victim was rendered unconscious (use of a sleeping substance alleged), was held handcuffed and chained inside the Bacoor house for twenty-two days, and ransom demands (US$600,000 and Php20,000/day) were made and communicated to the victim’s family.

Accomplice Liability Analysis Regarding Susana

Applying Article 18 of the RPC and relevant jurisprudence, the Court concluded Susana acted as an accomplice rather than a principal. The prosecution evidence established that she knew of the criminal design, remained silent, and supplied material and moral aid by staying in the house and providing or accompanying the delivery of food to the detained victim. The Court emphasized that giving food was not es

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