People of the Philippines v. Muit

Posted Oct 8, 2008

By Anonymous

7 min read

Case Title and Citation

People of the Philippines, appellee, vs. MILLANO MUIT y MUÑOZ, SERGIO PANCHO y CAGUMOC, JR., ROLANDO DEQUILLO y TAMPOS, ROMEO PANCHO, and EDUARDO HERMANO alias “Bobby Reyes,” ROLANDO DEQUILLO, JOSEPH FERRAER.
G.R. No. 181043, October 8, 2008
Supreme Court - Second Division
Ponente: Justice Tinga

Facts

On 11 November 1997, Orestes Julaton arrived at Ferraer’s house in Nasugbu, Batangas with Sergio Pancho Sr., Pancho Jr., Dequillo and four others aboard a gray Mitsubishi PSV-818. Julaton introduced them to Ferraer and explained Pancho Sr. wanted to use Ferraer’s house as a safehouse for their “visitor.” Ferraer initially hesitated, but Hermano reassured him that their work was kidnapping for ransom and that the money would be shared equally; Ferraer and Pancho Sr. would guard the victim.
Five additional men later joined, identified to Ferraer as Muit, Morales (alias Tony), alias David, and alias Puri. They had dinner and discussed plans; Morales handed to Ferraer a carton wrapped with masking tape and a green backpack containing firearms; Ferraer inspected the guns and stored them under his bed.
By 2 December 1997, the group learned the victim was at the construction site in Tanauan, Batangas. Hermano, Morales, Udon, Manuel, Bokbok, and Muit traveled to the site; Pancho Jr. was in the Mitsubishi as back‑up. The victim’s driver, Roger Seraspe, and Chavez were at the site; the group abducted the victim after ensuring the victim and Engr. Ruth Roldan were present.
The Pajero with the victim and Ruth Roldan was driven away; police were alerted and a barricade was set at Lipa City. A firefight ensued when the Pajero was intercepted; all occupants of the Pajero died except the driver and front passenger who escaped. Muit was arrested nearby.
Pancho Jr. returned to Ferraer’s house after the group failed to show up for a planned meeting. The news later reported the shootout and the Pajero’s destruction; several suspects including Muit were subsequently arrested. Ferraer testified and was utilized as a state witness; several extra-judicial confessions were obtained from Pancho Jr. and Dequillo, with assistance from Atty. Mallare.
The defense presented Dequillo, Pancho Jr., and Muit, who claimed they had non-participatory roles or were tortured into confessions. Muit claimed he was elsewhere on 2 December 1997 and denied knowledge of the crimes. They asserted the extra-judicial confessions were coerced and unconstitutionally obtained.
In 2002, the RTC convicted Muit, Pancho Jr., Dequillo, and Romeo of kidnapping for ransom with homicide and carnapping, relying on eyewitness accounts, Ferraer’s testimony, and extrajudicial confessions. The Court of Appeals affirmed in 2007, with death sentences for kidnapping for ransom with homicide and carnapping.
The case proceeds to automatic review before the Supreme Court. The Court ruled on issues of guilt beyond reasonable doubt, conspiracy, admissibility and weight of extrajudicial confessions, and the penalties and damages, including adjustments due to abolition of the death penalty.

Issues

Did the RTC err in finding the appellants guilty beyond reasonable doubt?
Was there conspiracy among the appellants to commit kidnapping for ransom with homicide and carnapping?
Did the RTC err in giving credence to the extra-judicial confessions of Pancho Jr., Dequillo, and to Ferraer’s sworn statements and testimony?

Ruling

Yes — The totality of the prosecution’s evidence established the commission of kidnapping for ransom with homicide and carnapping beyond reasonable doubt.
Yes — Conspiracy was proven; the group planned the kidnapping in Ferraer’s house, awaited the victim, and executed the plan in concert with one another.
Yes — The extra-judicial confessions, supported by counsel and corroborated by independent witnesses and other evidence, were properly admitted and found credible; the interlocking confessions and corroboration by eyewitness testimony strengthened the case.

Reasoning / Ratio Decidendi

The elements of kidnapping for ransom and serious illegal detention require (a) a private individual, (b) deprivation of liberty, (c) illegality, and (d) aggravating circumstances or intent to extort. The prosecution established these elements through direct testimony by Ferraer, Seraspe, and Chavez, and through the victim’s forcible abduction at the construction site and the subsequent reporting to authorities.
The Anti-Carnapping Act defines carnapping as taking a motor vehicle with intent to gain, by violence or intimidation, or using force upon things. The Pajero was forcibly taken in conjunction with the kidnapping, satisfying the offense.
Conspiracy existed as a unity of purpose among the accused; the group planned at Ferraer’s house, coordinated movements, and executed the kidnapping with shared objectives. Conspiracy is proven by circumstantial evidence when multiple conspirators share a common plan and act in concert.
Extrajudicial confessions: overlapping confessions among Pancho Jr., Dequillo, and Muit were admissible as circumstantial evidence and as corroboration where supported by other independent evidence, per established jurisprudence on interlocking confessions.
Torture claims were rejected due to lack of corroborating medical evidence; the statements were voluntary and the accused were assisted by counsel.
Penalties: RA 9346 abolishes the death penalty; the court commuted death sentences to reclusion perpetua, with access restrictions under Act No. 4103. The court also considered aggravating circumstances, including that the kidnapping was for ransom and the carnapping involved a band of armed offenders.
Damages: The court adjusted damages, removing loss of earning capacity due to lack of adequate proof, increasing civil indemnity to ₱75,000, elevating moral damages to ₱500,000, and awarding temperate damages to heirs (₱25,000) with exemplary damages (₱100,000 for kidnapping for ransom with homicide and ₱25,000 for carnapping). Costs were assessed against the appellants.

Doctrine / Legal Principle

Conspiracy: A unity of purpose and intention among conspirators makes the acts of one the acts of all; the degree of participation becomes secondary when conspiracy is proven.
Interlocking/Interdependent Confessions: Multiple extrajudicial statements by co-defendants may be admissible as corroborative evidence if supported by other facts and do not imply coercion; identical confessions enhance probative value as corroboration.
Voluntariness of confessions: The voluntariness of extrajudicial statements is supported by presence of counsel and the absence of credible evidence of coercion or torture.
Kidnapping and Ransom: The deprivation of liberty for purposes of ransom, even without a formal demand or payment, constitutes kidnapping for ransom with homicide where a killing occurs during the crime.
Carnapping: As defined by the Anti-Carnapping Act, the taking of a motor vehicle with intent to gain using force or intimidation constitutes carnapping; aggravating circumstances (like a band of multiple armed offenders) influence the penalty.
Death Penalty Abolition: The death penalty was abolished; sentences are reduced to reclusion perpetua with related penalties and restrictions.
Damages in criminal cases: When proof of actual damages is insufficient, temperate damages may be awarded; civil indemnity is payable by the offenders; moral and exemplary damages may be awarded under appropriate circumstances; and loss of earning capacity requires adequate proof.

Disposition

The Decision of the Court of Appeals is AFFIRMED with the following MODIFICATIONS:
- The compensation for loss of earning capacity is deleted.
- Civil indemnity increased to ₱75,000.00.
- Moral damages increased to ₱500,000.00.
- Appellants shall pay temperate damages of ₱25,000.00 to the heirs of Ignacio Earl Ong, Jr.
- Exemplary damages of ₱100,000.00 for kidnapping for ransom with homicide and ₱25,000.00 for carnapping.
The death penalties imposed by the RTC/CA are commuted to reclusion perpetua without eligibility for parole (consistent with abolition of the death penalty).
Costs against appellants.

Concurring / Dissenting Opinions

The decision was joined by Justices Leonardo A. Quisumbing, Conchita Carpio Morales, Presbitero J. Velasco, Jr., Arturo D. Brion, among others, as indicated in the opinion and attestations.

Significance / Notes

Reiterates the standard for proving conspiracy and the admissibility framework for interlocking extrajudicial confessions.
Affirms application of RA 9346, converting death sentences to reclusion perpetua, and clarifies the related penalties and monetary awards in line with jurisprudence on damages and indemnities.
Demonstrates the weight given to eyewitness testimony and corroborating witnesses when evaluating kidnapping for ransom with homicide and carnapping cases.
Highlights the evidentiary approach to police investigations and the treatment of alleged coercion or torture claims in extrajudicial confessions.

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