Case Summary (G.R. No. 264958)
The Charge
Delos Reyes faced charges of serious illegal detention as defined under Article 267 of the Revised Penal Code. The charge stated that he unlawfully detained a 15-year-old minor, referred to here as AAA264958, against the latter's will from October 23 to October 25, 2014, in Bataan.
Proceedings in the Regional Trial Court
The case was assigned to the Regional Trial Court, Branch 94, in Bataan. Delos Reyes entered a plea of not guilty during the arraignment. The trial included testimonies from several witnesses, including the minor victim, along with evidence provided by the prosecution and defense.
Prosecution's Narrative
AAA264958 testified that on October 23, 2014, he was taken by Delos Reyes to collect money from a contact named Sherlyn. During their wait at a location in Bataan, Delos Reyes engaged in a drinking session. After waiting most of the day, when AAA264958 suggested they leave, Delos Reyes threatened him with a knife, leading to a forced relocation to a Triskellion Fraternity camp where AAA264958 was restrained and pushed into a pit.
Defense's Position
Delos Reyes countered by stating that AAA264958 willingly visited him to see friends. He described that they had lunch together and went to the area with permission. He claimed that the arrest on October 25, 2014, by police officers was without the disclosure of the reason for his detention.
Ruling of the Regional Trial Court
The trial court ruled on May 22, 2019, finding Delos Reyes guilty of serious illegal detention. He was sentenced to reclusion perpetua and required to pay the corresponding legal costs.
Ruling of the Court of Appeals
On appeal, the Court of Appeals upheld the trial court's decision but also awarded PHP 75,000 each as civil indemnity and moral and exemplary damages to the victim. The appellate court's decision was rendered on May 26, 2021.
The Present Appeal
In the current appeal, Delos Reyes sought acquittal but both parties agreed to adopt their briefs previously filed in the Court of Appeals rather than submitting new supplemental briefs.
Legal Basis for Ruling
Article 267 of the Revised Penal Code, amended by Republic Act No. 7659, defines serious illegal detention and prescribes harsh penalties for violations. The elements of the crime established include: the offender being a private individual, deprivation of liberty, the illegal nature of such detention, and specific aggravating circumstances, which in this case relate to the victim being a minor.
Findings and Conclusions
The appellate court found that all elements of serious illegal detention were satisfied. The prosecution's narrative was substantiated by clear and convincing testimony from AAA264958, and
...continue readingCase Syllabus (G.R. No. 264958)
The Case
- This appeal concerns G.R. No. 264958, decided on August 14, 2023.
- The appeal challenges the decision of the Court of Appeals dated May 26, 2021, which affirmed the conviction of Jonnel Delos Reyes y Tungol (Delos Reyes) for serious illegal detention under Article 267 of the Revised Penal Code.
Antecedents
- Delos Reyes was charged with serious illegal detention as defined under Article 267 of the Revised Penal Code, in relation to Republic Act No. 7610.
- The charge specified that from October 23 to October 25, 2014, in Bataan, Delos Reyes unlawfully detained a minor, AAA264958, causing child abuse.
The Charge
- The Regional Trial Court, Branch 94 in Bataan, handled the case after it was raffled to them.
- During the arraignment, Delos Reyes pleaded not guilty, leading to the trial where testimonies were presented by both the prosecution and defense.
Version of the Prosecution
- The prosecution presented the testimony of the private complainant, AAA264958, alongside witnesses Ciara Sumera, Miriam Sanchez, and Police Officer III Darwin Ortega.
- AAA264958 recounted that on October 23, 2014, he went with Delos Reyes to collect money, part of his initiation into the Triskellion Fraternity.
- After waiting for Sherlyn to arrive and becoming frustrated, AAA264958 was threatened with a knife by Delos Reyes, who then took him to a Triskellion camp.
- Delos Reyes forcibly tied AAA264958's hands and blindfolded him, subsequently pushing him into a 20-foot deep pit.
- AAA264958 managed to escape