**Facts:**
On February 8, 1978, Leon Marajas, Jr. along with companions kidnapped a 14-year-old boy, Francis Banaga, under the guise of a casual invitation. Using a car driven by their accomplice, Padica, they coerced Banaga and another boy, Eddie Boy Marajas, into boarding the vehicle and subsequently drove them to a desolate sugarcane plantation in Calamba, Laguna. Upon arrival, the group forcibly pulled Banaga from the car and executed him with stabbing and gunshot wounds. Following the murder, a ransom demand for P500,000 was made to Banaga’s family; this demand was later reduced to P23,000. The police enacted a sting operation, leading to the arrest of Leon Marajas, Jr. when he accepted the ransom money from Camello, a relative of the Banaga family.
Procedurally, an initial information was filed excluding Leon Marajas, Jr., which was later amended to include his name. After several legal maneuvers, including discharge of other co-accused to be state witnesses and various motions, the trial concluded in 1990 with a guilty verdict against Leon Marajas, Jr. for kidnapping for ransom with murder. He was sentenced to reclusion perpetua.
**Issues:**
1. Whether the trial court erred in finding Leon Marajas, Jr. guilty of kidnapping for ransom with murder.
2. Whether the trial court erred in accepting the testimony of Romeo Padica.
3. Whether Leon Marajas, Jr.’s defense of alibi and claim of frame-up were sufficiently discredited.
4. Procedural validity concerning amendments to the information and inclusion of the appellant’s real name.
**Court’s Decision:**
1. **Nature of the Crime:**
– The Supreme Court determined that the crime was not kidnapping for ransom but was purely murder, characterized by treachery and abuse of superior strength. The primary intent was to kill, with the ransom demand being an afterthought. Hence, it could not be considered a complex crime of kidnapping with murder.
2. **Credibility of Witness Testimony:**
– The trial court’s favorable assessment of Romeo Padica’s testimony was upheld. The Court found his statements consistent and devoid of ill-motive against Leon Marajas, Jr., despite the latter’s arguments attempting to discredit Padica.
3. **Defense of Alibi:**
– The Court found the alibi presented by Leon Marajas, Jr. unreliable and not adequately corroborated. Positive identification by witnesses outweighed his negative defense of alibi.
4. **Procedural Issues:**
– Leon Marajas, Jr. waived his right to challenge the sufficiency of the information by failing to file a motion to quash at the proper time. The subsequent amendment correctly included his real name, and the procedural integrity of his arraignment and trial was maintained.
**Doctrine:**
1. **Kidnapping vs. Murder:**
– The essential element of kidnapping is restrained liberty, and where the primary intent is to kill, with any subsequent ransom demand being secondary, the crime is solely murder (People vs. Masilang, et al.).
2. **Positive Identification vs. Alibi:**
– Positive identification by credible witnesses outweighs negative assertions like alibi, which must establish both presence in another location and the impossibility of being at the crime scene.
3. **Procedural Regularities:**
– Defects in the name of the accused in the information can be corrected by amendment, provided they do not alter the nature of the offense, and any challenge to jurisdiction over the person due to such defects must be timely raised.
**Class Notes:**
– Treachery: Sudden and unexpected attack on an unsuspecting victim.
– Abuse of Superior Strength: Deliberate use of force greater than necessary to ensure no defense or escape.
– Reclusion Perpetua: Severe penalty, akin to life imprisonment.
– Elements of Alibi as Defense: Presence elsewhere and physical impossibility to be at the crime scene.
– Police Entrapment: Legally sanctioned strategy to apprehend a suspect during the commission of an offense.
**Historical Background:**
This case takes context during the martial law era in the Philippines (1972-1981), where crimes such as kidnappings had heightened societal impact and judicial proceedings often entailed unusual delays or complex legal tactics. The case also underscores the increasing judicial scrutiny on procedural integrity and thoroughness in criminal investigations amidst a period marked by stringent measures and human rights issues.
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