**Facts:**
1. **December 27, 1998:** Antonio Siongco induced 11-year-old Nikko Satimbre to board a bus to Pilar, Bataan, promising him a “Gameboy.” Nikko’s mother Elvira was unaware of his whereabouts and reported him missing.
2. **December 28, 1998:** Siongco, Eriberto Enriquez, and Nikko traveled to Manila. Elvira received a call from Siongco demanding P400,000 for Nikko’s release, later reduced to P300,000.
3. **December 30, 1998:** Siongco and Enriquez moved Nikko to Pateros. Elvira continued negotiations with the captors and reported the kidnapping to the police.
4. **December 31, 1998:** Siongco and Enriquez planned a ransom exchange at the Genesis Bus Station. Police, with the cooperation of Elvira, apprehended Enriquez as he collected the fake ransom and later arrested Siongco in Pateros, rescuing Nikko.
5. **January 4, 1999:** An Information was filed charging Siongco and Bonsol, among others, with kidnapping and serious illegal detention under Article 267 of the Revised Penal Code.
6. **February 24, 1999:** Accused pleaded not guilty, and trial commenced. The prosecution presented various witnesses, while the accused denied the charges.
7. **November 6, 2000:** The Regional Trial Court (RTC) found Siongco, Bonsol, Enriquez, and Hayco guilty and sentenced them to death, later appealed.
8. **September 20, 2007:** The Court of Appeals (CA) affirmed the RTC conviction but modified the penalty to reclusion perpetua and adjusted the damages.
9. **September 29, 2008:** CA declared the conviction of Enriquez and Hayco final, while continuing with Siongco and Bonsol’s appeal.
**Issues:**
1. **Existence of illegal detention or deprivation of liberty.**
2. **Minority and consent of the victim, Nikko.**
3. **Proof of conspiracy among the accused.**
4. **Validity of the procedural representation by counsel during the trial.**
5. **Correctness of the penalties and damages awarded by the lower courts.**
**Court’s Decision:**
1. **Illegal Detention:** The Supreme Court validated the deprivation of liberty, emphasizing the minor’s restricted movements and the captors’ control despite some freedom to play.
2. **Minority and Consent:** As Nikko was only 11 years old, he was legally incapable of giving consent, and the Court underscored that any apparent consent given on false pretenses still constituted illegal detention.
3. **Conspiracy:** The Court found sufficient evidence establishing the conspiracy. Each accused played a distinct role in the kidnapping scheme, proving collective intent and action toward the unlawful detention and ransom demand.
4. **Procedural Representation:** The Court deemed the temporary representation by Atty. Moralde as adequate, ensuring continuity during the primary counsel’s absence, and found no evidence of prejudice against the appellants.
5. **Penalties and Damages:** Consistent with RA No. 9346, the death penalty was reduced to reclusion perpetua without parole. The moral damages awarded were increased to reflect the severity of the crime’s impact on the minor.
**Doctrine:**
The case reaffirmed that the essence of kidnapping under Article 267 of the Revised Penal Code includes any form of deprivation of liberty. Consent from a minor is legally void, and kidnapping can occur through fraud, not just force.
**Class Notes:**
– **Key Elements (Article 267, Revised Penal Code):**
1. Offender is a private individual.
2. Kidnaps/detains another or deprives them of liberty.
3. The detention is illegal.
4. Aggravating circumstances: duration of over three days, simulating public authority, infliction of serious physical injuries/threats, or when the victim is a minor.
5. The intent of extorting ransom enhances the penalty.
– **Statutory Provisions:**
– **Article 267 of the Revised Penal Code:** Specific to kidnapping and serious illegal detention.
– **RA No. 9346:** Prohibits the imposition of the death penalty, mandating reclusion perpetua as the maximum sentence.
**Historical Background:**
This case is set against a backdrop of stricter anti-kidnapping efforts in the Philippines during the late 1990s, amidst rising reports of such crimes. The Revised Penal Code and subsequent amendments sought to address the severity and increase deterrent measures.
Leave a Reply