The actual deprivation of the victim's liberty, coupled with the indubitable proof of the accused's intent to effect such deprivation, and the victim being a minor, are sufficient to constitute the crime of serious illegal detention under Article 267 of the Revised Penal Code.

The case arose from an incident where the accused-appellant, Jonnel Delos Reyes, allegedly detained a 15-year-old minor, AAA264958, between October 23 and October 25, 2014, in Bataan. This detention was purportedly part of the minor's initiation into the Triskellion Fraternity, during which he was subjected to acts that deprived him of his liberty and constituted child abuse.

• On October 23, 2014, AAA264958, a 15-year-old, accompanied Jonnel Delos Reyes to collect money as part of his initiation into the Triskellion Fraternity.
• They went to a location in Bataan around 11:00 a.m., where Delos Reyes joined a drinking session while waiting for a certain Sherlyn.
• When Sherlyn failed to appear by 5:30 p.m., AAA264958 asked to go home, but Delos Reyes pointed a knife at him and took him to the nearby Triskellion Fraternity camp.
• At the camp, Delos Reyes tied AAA264958's hands with a nylon cord, covered his eyes and mouth with pieces of cloth, and ordered him to take 10 steps forward.
• On the fourth step, Delos Reyes pushed AAA264958 into an open pit about 20 feet deep.
• AAA264958 managed to extricate himself from the pit two days later, on October 25, 2014.
• He immediately sought help at the barangay hall and was subsequently accompanied to the municipal police station to report the incident.
• Delos Reyes, in his defense, claimed that on October 24, 2014, AAA264958 went to his house and asked to be accompanied to meet friends in Bataan. He stated they went there, AAA264958's friends were swimming, and he asked to go home around 4:30 p.m.
• Delos Reyes further claimed that on October 25, 2014, AAA264958, accompanied by police officers, came to his house, and he was arrested without reason.
• The parties stipulated that AAA264958 was 15 years old at the time of the incident, and his age was established by his Certificate of Live Birth.

• Delos Reyes disputed the findings of the lower courts, particularly questioning the absence of any finding in the medical certificate of AAA264958 that he suffered any mark or injury on his wrists, despite claiming to have exerted effort to loosen the nylon binding his hands.
• Delos Reyes pleaded for his acquittal, adopting his brief before the Court of Appeals.

• The People of the Philippines, through the Office of the Solicitor General, argued that all elements of serious illegal detention were established to a moral certainty by the clear, straightforward, and convincing testimony of AAA264958.
• The prosecution maintained that Delos Reyes is a private individual, he deprived AAA264958 of his liberty, the detention was illegal, and the victim was a minor.
• The prosecution asserted that the methodical manner employed by Delos Reyes showed a deliberate intent to deprive AAA264958 of his liberty.
• The prosecution contended that the alleged discrepancy regarding the absence of wrist marks in the medical certificate is a trivial matter irrelevant to the elements of the crime and that inconsistencies on immaterial details do not negate the probative value of a witness's testimony.

• Whether the Court of Appeals erred in affirming the conviction of Jonnel Delos Reyes for serious illegal detention.
• Whether all the elements of the crime of serious illegal detention under Article 267 of the Revised Penal Code were proven beyond reasonable doubt.

• The Supreme Court dismissed the appeal and affirmed in full the decision of the Court of Appeals.
• The Court found that all elements of serious illegal detention were established: (a) Delos Reyes is a private individual; (b) he deprived AAA264958 of his liberty by tying his hands, blindfolding him, and pushing him into a 20-foot pit from which he escaped two days later; (c) the act of detention was illegal, not being ordered by any competent authority nor allowed by law; and (d) the person kidnapped or detained (AAA264958) was a minor, being 15 years old at the time.
• The Court held that the methodical manner employed by Delos Reyes demonstrated a deliberate intent to deprive AAA264958 of his liberty.
• The Court found the testimony of AAA264958 to be clear, straightforward, and convincing, and gave great weight to the factual findings of the trial court, especially since they were affirmed by the Court of Appeals.
• The Court dismissed Delos Reyes' argument regarding the absence of wrist marks in the medical certificate as a trivial matter irrelevant to the elements of the crime, stating that inconsistencies on immaterial details do not negate the probative value of testimony.
• The penalty of reclusion perpetua was correctly imposed as, under Article 63 of the Revised Penal Code, when the law prescribes a penalty composed of two indivisible penalties (reclusion perpetua to death for serious illegal detention) and there are no mitigating or aggravating circumstances, the lesser penalty shall be applied.
• The award of PHP 75,000.00 each for civil indemnity, moral damages, and exemplary damages was affirmed, consistent with People v. Jugueta.

• Elements of Serious Illegal Detention (Article 267, Revised Penal Code) — The crime requires: (a) the offender is a private individual; (b) he or she kidnaps or detains another, or in any manner deprives the latter of his liberty; (c) the act of detention is illegal; and (d) any of the qualifying circumstances is present (e.g., detention lasts more than three days, victim is a minor). The Court found all these elements present, emphasizing the victim's minority and the actual deprivation of liberty.
• Essence of Serious Illegal Detention — The essence of this crime is the actual deprivation of the victim's liberty, coupled with indubitable proof of the accused's intent to effect such deprivation. The Court found Delos Reyes' actions of tying, blindfolding, and pushing the victim into a pit demonstrated this intent and resulted in actual deprivation of liberty.
• Credibility of Witnesses and Factual Findings of Trial Courts — Factual findings of the trial court regarding the credibility of witnesses are entitled to great weight and respect, especially when affirmed by the appellate court, absent any showing that the trial court overlooked facts that could substantially affect the outcome. The Supreme Court found no reason to depart from this rule in this case.
• Immaterial Inconsistencies — Inconsistencies on immaterial details do not negate the probative value of a witness's testimony regarding the very act of the accused. The Court applied this by stating that the alleged lack of wrist marks on the victim was a trivial matter irrelevant to the elements of serious illegal detention.
• Application of Penalties (Article 63, Revised Penal Code) — In cases where the law prescribes a penalty composed of two indivisible penalties, and there are neither mitigating nor aggravating circumstances, the lesser penalty shall be applied. This was applied to impose reclusion perpetua, as the crime of serious illegal detention (when the victim is a minor) is punishable by reclusion perpetua to death, and no modifying circumstances were found.

• "The Court has consistently decreed that the essence of serious illegal detention is the actual deprivation of the victim's liberty, coupled with the indubitable proof of intent of the accused to effect such deprivation."
• "It is well settled that the factual findings of the trial court as regards its assessment of the credibility of witnesses are entitled to great weight and respect by the Court, particularly when the same carry the full concurrence of the appellate court, absent any showing that the trial court overlooked certain facts and circumstances which could substantially affect the outcome of the case as here."
• "Verily, inconsistencies on immaterial details do not negate the probative value of the testimony of a witness regarding the very act of the accused."

• Alberto v. Court of Appeals (711 Phil. 530 (2013)) — Cited for enumerating the elements of the crime of serious illegal detention.
• People v. Ali (822 Phil. 406 (2017)) — Cited for the principle that the essence of serious illegal detention is the actual deprivation of the victim's liberty and the accused's intent, and that immaterial inconsistencies do not negate probative value.
• People v. Anticamara (666 Phil. 484 (2011)) — Cited for the definition of deprivation of liberty, which includes not only placing a person in an enclosure but also detaining or depriving them of liberty in any manner.
• People v. Baluya (664 Phil. 140 (2011)) — Cited for the doctrine that factual findings of the trial court on witness credibility are given great weight, especially when affirmed by the Court of Appeals.
• People v. Jugueta (783 Phil. 806 (2016)) — Cited as the basis for the amounts awarded for civil indemnity, moral damages, and exemplary damages.

• Article 267 of the Revised Penal Code, as amended by Republic Act No. 7659 — Defines the crime of serious illegal detention and prescribes the penalty. This is the primary article under which the accused was charged and convicted.
• Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act) — Mentioned in the charge information as the crime was committed against a minor, subjecting him to child abuse.
• Article 63 of the Revised Penal Code — Provides rules for the application of indivisible penalties. Specifically, paragraph 2 was applied, stating that when there are neither mitigating nor aggravating circumstances, the lesser of two indivisible penalties shall be imposed.