People v. Licayan
REITERATIONFacts
The Antecedents: Complainants Joseph Tomas Co and Linda Manaysay, owner and cashier/accounting officer of Goodies Pares Mami House, respectively, were conducting their usual late-night rounds of the restaurant branches. On August 10, 1998, at around 1:45 a.m., while at the Sampaloc branch, three armed men approached Co. Despite Co's offer to take money from the store, the men refused. A gun was fired, and Manaysay came out. The complainants were forced into the rear of Co's Tamaraw FX, with their hands tied and eyes taped. They were taken to a house in Marikina where their eyes were uncovered, and their feet were tied. Their personal belongings, including cash, a watch, a bank time deposit certificate, and jewelry, were taken. They identified accused-appellants Roderick Licayan and Roberto Lara as among their abductors and guards. Lara guarded them initially, and Licayan guarded them the following day. The complainants managed to escape and sought refuge in a house, from where Co called the Marikina Police. On August 11, 1998, the Presidential Anti-Organized Crime Task Force (PAOCTF) raided the safehouse and arrested Roberto Lara. Lara identified Licayan as a companion, leading to Licayan's arrest. Both were identified by the complainants in a police line-up. Benjamin Co, Joseph Co's brother, testified that he received demands for P10 million for the complainants' release. Procedural History: The Regional Trial Court (RTC), Branch 272, Marikina City, found accused-appellants Roderick Licayan and Roberto Lara guilty of Kidnapping for Ransom under Article 267 of the Revised Penal Code, as amended, and sentenced them to suffer the penalty of death. They were acquitted of Robbery. The RTC ordered them to indemnify the private complainants. The Petition: Accused-appellants appealed, contending that the RTC erred in giving full credence to the prosecution witnesses' testimonies despite inconsistencies, in not ruling that their arrest was illegal, and in finding them guilty of conspiracy as principals when their participation was limited to that of mere accomplices.
Issue(s)
Whether the RTC gravely erred in giving full credence to the testimonies of prosecution witnesses despite alleged manifest inconsistencies regarding the identification of the accused-appellants. Whether the accused-appellants were illegally arrested and whether their warrantless arrest falls under the exceptions provided by law, including the implications of their plea and participation in the trial, and the admissibility of extra-judicial confessions. Whether the accused-appellants acted in conspiracy as principals or were merely accomplices in the commission of the crime of kidnapping for ransom, and the propriety of the damages awarded by the RTC.
Ruling
The Supreme Court affirmed the decision of the RTC finding accused-appellants Roderick Licayan and Roberto Lara guilty beyond reasonable doubt of Kidnapping for Ransom, sentencing each to death. The Court modified the award of damages, ordering each accused-appellant to pay P50,000.00 as moral damages to each complainant and deleted the award of P20,000.00 as actual damages.
Ratio Decidendi
On the credibility of prosecution witnesses and identification of accused-appellants: The Court held that the assessment of evidence by the trial court is given the highest degree of respect. The alleged failure of complainants to remember physical features was immaterial, as their positive identification of the accused-appellants was crucial. Complainant Co identified Lara as their guard and Licayan as guarding them the next day. Manaysay identified Licayan and Lara as the persons she saw when the tape was removed. Both complainants positively identified the accused-appellants in a police line-up. The defense of alibi was rejected as weak when the accused's identity is satisfactorily established. On the legality of the arrest: The Court ruled that accused-appellants were estopped from questioning the legality of their arrest because they voluntarily submitted to the jurisdiction of the trial court by pleading not guilty and participating in the trial without moving to quash the information. Any irregularity in the warrantless arrest was cured by their voluntary submission. Regarding the claim of not being assisted by counsel during custodial investigation, the trial court found that Roberto Lara's participation in the commission of the crime was made voluntarily, with assistance from counsel de officio, complying with constitutional requirements. The extra-judicial confession, though admissible only against the confessant, could serve as corroborative evidence. On conspiracy and the role of accused-appellants and damages: The Court rejected the argument that accused-appellants were mere accomplices. Conspiracy can be inferred from the acts of the accused pointing to a joint purpose, design, concerted action, and community of interests. By guarding the victims and preventing their escape, the accused-appellants exhibited knowledge of the criminal design and participated in its execution. The crime proven was kidnapping for ransom, punishable by death under Article 267 of the Revised Penal Code. The Court affirmed the RTC's finding of guilt but modified the award of damages. An award of P50,000.00 as moral damages to each complainant was deemed proper. Exemplary damages were disallowed due to the absence of aggravating circumstances. The award of actual damages was also deleted for failure to present evidence to sustain it with certainty.
Main Doctrine
The positive identification of the accused by the victim is given the highest degree of respect. Alibi, being an inherently weak defense, must fail when the accused's identity is satisfactorily and categorically established by eyewitnesses. Any irregularity in a warrantless arrest is cured by the accused's voluntary submission to the trial court's jurisdiction by entering a plea and participating in the trial. Conspiracy can be inferred from the concerted actions and community of interest of the accused, even without direct proof. The crime of kidnapping for ransom under Article 267 of the Revised Penal Code, as amended by R.A. 7659, is punishable by death if committed for the purpose of extorting ransom. Awards for moral damages are proper, but exemplary damages require aggravating circumstances, and actual damages must be proven with certainty.