People v. Tadah
REITERATIONFacts
The Antecedents: The appellant, Yusop Tadah, was convicted by the Regional Trial Court (RTC) of Zamboanga for five counts of kidnapping and serious illegal detention. The victims were Gina Yang y Bersañez, 3-year old Princess Jane "Cha-Cha" Yang, Joy Sagubay, Yang Wang Tao Chiu, and Nicomedes Santa Ana. The RTC gave credence to the testimonies of the victims, Nicomedes and "Cha-Cha," who positively identified the appellant as one of their kidnappers. The RTC found that conspiracy attended the crime, that the kidnapping was committed for ransom, and that motorized vehicles and watercrafts were used. The appellant was sentenced to the death penalty for each count. Procedural History: The Court of Appeals (CA) affirmed the RTC's decision but reduced the sentence to reclusion perpetua in accordance with Republic Act (RA) No. 9346, the Anti-Death Penalty Law. The Petition: The appellant filed an appeal before the Supreme Court.
Issue(s)
Whether the appellant's guilt for five counts of kidnapping and serious illegal detention was proven beyond reasonable doubt. Whether the penalty imposed by the CA, reclusion perpetua, is the correct penalty considering the aggravating circumstances and the provisions of RA No. 9346, and whether the appellant is eligible for parole. Whether the award of civil indemnity, moral damages, and exemplary damages is proper, and if so, in what amounts.
Ruling
The Supreme Court denied the appeal, affirmed the decision of the Court of Appeals with modification, and found the appellant guilty beyond reasonable doubt of five counts of kidnapping and serious illegal detention. The appellant was sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole, for each count. The appellant was also ordered to pay restitution of ₱2,000,000.00 for the ransom paid, and to each victim, ₱75,000.00 as civil indemnity, ₱75,000.00 as moral damages, and ₱30,000.00 as exemplary damages.
Ratio Decidendi
On the guilt of the appellant: The Court found no reason to reverse the findings of the RTC, as affirmed by the CA. The testimonies of Nicomedes and "Cha-Cha" amply established the case for the prosecution. No motive affecting their credibility was imputed against them. The appellant's positive identification as one of the perpetrators rendered his defense of alibi unworthy of credit. The prosecution adduced proof beyond reasonable doubt that the accused conspired to kidnap the victims for ransom, and illegally detained them until their release upon payment of ₱2,000,000.00. On the penalty imposed: The imposable penalty for kidnapping and serious illegal detention for ransom is death under Article 267 of the Revised Penal Code. However, the CA correctly reduced the appellant's sentence from the death penalty to reclusion perpetua due to the passage of RA No. 9346, which prohibits the imposition of the death penalty. Furthermore, under Section 3 of RA No. 9346, persons convicted of offenses punished with reclusion perpetua, or whose sentences are reduced to reclusion perpetua by reason of this Act, are not eligible for parole under Act No. 4180. On the civil liability: The Court found it necessary to modify the appellant's civil liability in line with prevailing jurisprudence. The appellant is liable for ₱75,000.00 as civil indemnity, which is awarded when the crime warrants the imposition of the death penalty. He is also liable for ₱75,000.00 as moral damages, as the victim is assumed to have suffered moral injuries without need of proof. Additionally, ₱30,000.00 as exemplary damages is awarded to set an example for the public good, for each count of kidnapping and serious illegal detention.
Main Doctrine
The penalty for kidnapping and serious illegal detention, even with aggravating circumstances, is reclusion perpetua without eligibility for parole, pursuant to RA No. 9346, and the award of civil indemnity, moral damages, and exemplary damages is mandatory.