People of the Philippines vs. Eduardo Pavillare y Varona
### Facts:
On February 12, 1996, Sukhjinder Singh was kidnapped in Quezon City, Philippines, by Eduardo Pavillare y Varona and co-accused Sotero Santos y Cruz, along with unidentified accomplices, demanding a ransom of P20,000. The case landed in the Regional Trial Court of Quezon City, Branch 219, after both accused pleaded “not guilty” on April 29, 1996. The trial proceeded solely against Pavillare after a motion to dismiss based on witness identification failure led to Santos’s acquittal on February 28, 1997.
Singh’s testimony detailed his forced entry into a taxi cab, being detained, and the demand for ransom, which resulted in family negotiating and paying P25,000. Singh recognized Pavillare as the main perpetrator. Likewise, Lakhvir Singh, the complainant’s cousin, confirmed the transaction and pointed out Pavillare in court. After a line-up identification and Pavillare’s subsequent arrest on a separate but similar charge, the Regional Trial Court found Pavillare guilty of kidnapping for ransom and sentenced him to death, along with ordering compensation to the victim.
Pavillare’s appeal to the Supreme Court was based on questioning the credibility of witness identification, arguing his arrest and identification were influenced by a need for a “scapegoat” in a series of similar crimes involving Indian nationals. He also contended for a conviction of simple robbery instead of kidnapping for ransom.
### Issues:
1. Whether the identification of Pavillare by the complainant in a police line-up, conducted without legal counsel, is admissible.
2. Whether the eyewitness accounts credibly identified Pavillare as the perpetrator.
3. Whether Pavillare’s alibi was sufficient to counter the charge.
4. Whether the crime should be classified as kidnapping for ransom or simple robbery.
5. Legality of the death penalty under RA 7659.
### Court’s Decision:
The Supreme Court affirmed the lower court’s decision, addressing each issue systematically:
– The identification of Pavillare in the police line-up was deemed admissible as it fell outside the scope of custodial investigation requiring counsel.
– The credibility of eyewitness testimony, specifically Singh’s detailed recounting and Lakhvir Singh’s corroboration, was upheld.
– Pavillare’s alibi failed against direct witness identification, with the court noting that travel from his claimed location to the crime scene was plausible.
– The court rejected the notion that the motive was anything but ransom, thereby dismissing the argument for charging Pavillare with simple robbery.
– The death penalty was affirmed as the appropriate sentence, in line with RA 7659’s stipulations for kidnapping for ransom.
### Doctrine:
The decision reiterated that an uncounseled police line-up identification does not automatically invalidate subsequent in-court identifications. It also confirmed that eye witness accounts, when found credible, can outweigh alibi defenses. Furthermore, the court elucidated the nature of kidnapping for ransom, emphasizing that the deprivation of liberty for financial gain fulfills the crime’s definition under the Revised Penal Code.
### Class Notes:
– **Identification in Police Line-up:** Not considered part of the custodial investigation, thus not requiring the presence of counsel.
– **Witness Credibility and Identification:** Direct, positive identification by a credible witness can outweigh alibi defenses.
– **Kidnapping for Ransom:** Defined under the Revised Penal Code, Art. 267. The crime is constituted by the act of depriving someone of liberty with the intent of extorting ransom.
– **Death Penalty:** Upheld under RA 7659 for kidnapping for ransom, reflecting the gravity of crimes involving deprivation of liberty for financial gain.
### Historical Background:
The case showcases the legal process’s handling of kidnapping for ransom within the Philippines, emphasizing the procedural facets of witness identification, the role of eyewitness testimony in establishing guilt, and the application of the death penalty under specific criminal circumstances. This case also highlights the judicial system’s commitment to upholding the rule of law and ensuring justice for victims of serious crimes.
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