People vs. Reyes

The special complex crime of kidnapping for ransom with homicide is the correct nomenclature regardless of the number of deaths resulting from the kidnapping; the word "double" or similar modifiers should be deleted. Furthermore, an extrajudicial confession is admissible against a co-accused as corroborative circumstantial evidence where the confessions are independently made and interlocking.

On the night of July 16, 1999, the Yao family arrived at their poultry farm in Barangay Sto. Cristo, San Jose del Monte, Bulacan. As the patriarch, Yao San, alighted to open the gate, appellants Domingo Reyes and a certain Juanito Pataray approached him at gunpoint and dragged him into the family's Mazda MVP van. Appellants Alvin Arnaldo and Joselito Flores, along with armed companions, boarded the vehicle. Flores took the driver’s seat and drove the van while the family was blindfolded. The kidnappers eventually split the victims into two groups. Flores demanded ₱5,000,000 from Yao San for the release of the others. Although Yao San agreed to pay, the ransom drop at a dumpsite in Quezon City did not materialize as the kidnappers failed to appear. On July 23, 1999, the bodies of Chua Ong Ping Sim and Raymond Yao were found at the La Mesa Dam; both died of asphyxia by strangulation.

• The Abduction: On July 16, 1999, at around 11:00 p.m., the Yao family arrived at their poultry farm. Reyes and a cohort pinned Yao San at gunpoint and forced him into the van. Arnaldo, Flores, and others boarded the vehicle. Flores took the wheel while the armed men blindfolded the family using packaging tape.
• The Ransom Demand: After 30 minutes, the group stopped and split up. Flores held Yao San and some family members, demanding ₱5,000,000 for the release of Chua Ong Ping Sim, Robert, Raymond, and housemaid Jona Abagatnan. Reyes and Arnaldo guarded the victims in a mountainous safe-house. Robert was later released to locate Yao San and relay the ransom demand.
• The Failed Payoff: On July 19, 1999, the kidnappers instructed Yao San to bring the ransom to the Usan dumpsite. Yao San arrived, but the kidnappers never showed up and ceased communication.
• Discovery of the Victims' Bodies: On July 23, 1999, the corpses of Chua Ong Ping Sim and Raymond were discovered at the La Mesa Dam. Death certificates confirmed the cause of death as asphyxia by strangulation.
• Apprehension and Confessions: Arnaldo surrendered to the Presidential Anti-Organized Crime Task Force (PAOCTF) and executed an extrajudicial confession with the assistance of Atty. Uminga. Reyes was arrested and identified in a police line-up. Flores was arrested in Batangas and executed an extrajudicial confession with the assistance of Atty. Rous. Both confessions detailed the planning and execution of the kidnapping and implicated their co-accused.
• The Defense: Reyes and Flores interposed alibis, claiming they were asleep at their respective residences during the incident. Arnaldo claimed he was a PAOCTF asset framed for the crime after failing to remit drug sale proceeds. All three claimed their extrajudicial confessions were coerced and that their counsel were not of their own choosing.

• Credibility of Witnesses: Appellants argued that the prosecution witnesses could not have positively identified them because the incident occurred at night, the victims were blindfolded, and the kidnappers wore T-shirts over their heads. They also highlighted the victims' failure to immediately report the incident or identify the perpetrators to the authorities.
• Conspiracy: Appellants contended that the prosecution failed to prove conspiracy among them.
• Admissibility of Confessions: Appellants maintained that their extrajudicial confessions were inadmissible because they were obtained in violation of their constitutional right to independent counsel of their own choice. They alleged that the PAOCTF suggested the lawyers, that these lawyers were associated with the PAOCTF, and that the confessions were extracted through force and torture.
• Effect of Confessions on Co-Accused: Reyes argued that the confessions of Arnaldo and Flores could not be utilized against him, as extrajudicial confessions are admissible only against the confessant.
• Alibi and Frame-up: Reyes and Flores insisted their alibis cast reasonable doubt on their guilt, while Arnaldo asserted he was a victim of a frame-up by the PAOCTF.

• Credibility of Witnesses: The prosecution asserted that the victims positively identified the appellants because the crime scene was well-lit by a fluorescent bulb and the van's headlights and interior light, the blindfolds took 10 minutes to apply and later loosened, and the T-shirts worn by the kidnappers did not cover their faces. The delay in reporting was justified by the victims' fear for the lives of the hostages.
• Admissibility of Confessions: The prosecution argued that the confessions were voluntary and made with the assistance of competent and independent counsel. The PAOCTF properly apprised the appellants of their rights, and the lawyers who assisted them were private practitioners with no adverse interests.
• Corroboration: The prosecution maintained that the confessions were admissible against the co-accused as corroborative circumstantial evidence, as they constituted interlocking confessions.

• Credibility of Witnesses: Whether the prosecution witnesses could have positively identified the appellants given the circumstances of the kidnapping.
• Conspiracy: Whether conspiracy among the appellants was adequately proven.
• Admissibility of Confessions: Whether the extrajudicial confessions of appellants Arnaldo and Flores were obtained in compliance with constitutional safeguards on the right to counsel.
• Effect of Confessions on Co-Accused: Whether the extrajudicial confessions of Arnaldo and Flores are admissible against their co-accused, Reyes.
• Sufficiency of Alibi and Frame-up: Whether the defenses of alibi and frame-up prevail over the positive identification by prosecution witnesses.
• Nomenclature of the Crime: Whether the crime should be denominated as "kidnapping for ransom with double homicide."

• Credibility of Witnesses: The identification was ruled credible and trustworthy. The crime scene was illuminated by a fluorescent bulb and the van's headlights and interior light. It took the kidnappers approximately 10 minutes to blindfold all the victims, providing ample time to observe their faces. Furthermore, the victims' blindfolds occasionally loosened, and the T-shirts worn by the kidnappers did not cover their faces. The victims' failure to immediately report the incident was justified by the well-founded fear that the kidnappers would kill the hostages.
• Conspiracy: Conspiracy was established through the concerted acts of the appellants. Reyes and a cohort held Yao San at gunpoint, Flores drove the van, and Reyes and Arnaldo guarded the hostages and demanded ransom. Their acts demonstrated a unity of purpose and design in kidnapping the Yao family for ransom.
• Admissibility of Confessions: The extrajudicial confessions were admissible. The PAOCTF investigators properly informed the appellants of their constitutional rights in a language they understood. The counsel who assisted them were competent and independent; Atty. Uminga was a private practitioner and former NBI agent separated from the service, and Atty. Rous was a member of the IBP Free Legal Aid Committee. The constitutional phrase "preferably of his own choice" does not make the accused's choice exclusive, and counsel provided by investigators is deemed engaged when the accused does not object. The appellants failed to present credible evidence of coercion, as medical examinations yielded no signs of physical injury.
• Effect of Confessions on Co-Accused: The extrajudicial confessions of Arnaldo and Flores were admissible against Reyes as corroborative and circumstantial evidence. Under the doctrine of interlocking confessions, independently made confessions that are identical in their material respects are receivable as evidence to show the probability of a co-accused's participation. Even without these confessions, however, Reyes's guilt was sustained by the positive identification made by the prosecution witnesses.
• Sufficiency of Alibi and Frame-up: The defenses of alibi and frame-up were rejected. Alibi is the weakest defense and requires proof of physical impossibility of presence at the crime scene. Reyes lived in the same barangay where the crime occurred, and Flores could have easily traveled from Antipolo City to San Jose del Monte in two hours. Frame-up, like alibi, is easily concocted and was unsupported by clear and convincing evidence. Corroboration by relatives and friends was deemed less plausible due to partiality.
• Nomenclature of the Crime: The appropriate denomination of the crime is the special complex crime of kidnapping for ransom with homicide. The word "double" should be deleted, as the number of killings does not change the nomenclature of the special complex crime.

• Interlocking Confessions — Extrajudicial confessions independently made by co-accused, which are identical in their material respects and confirmatory of each other, are admissible as circumstantial evidence against a co-accused to show the probability of the latter's participation in the crime. They constitute an exception to the general rule that extrajudicial confessions are admissible only against the declarants thereof.
• Competent and Independent Counsel — The constitutional right to counsel "preferably of his own choice" does not convey that the choice of a lawyer is exclusive as to preclude other equally competent and independent attorneys from handling the defense. A lawyer provided by investigators is deemed engaged by the accused when the latter does not raise any objection to the appointment and thereafter subscribes to the veracity of the statement. Counsel is considered independent if they have no interest adverse to the accused, are not a special counsel or counsel of the police, and are willing to fully safeguard the constitutional rights of the accused.
• Kidnapping for Ransom with Homicide — Regardless of the number of killings or deaths that occur as a consequence of the kidnapping, the appropriate denomination of the crime is the special complex crime of kidnapping for ransom with homicide, without modifiers such as "double."

• "The phrase 'preferably of his own choice' does not convey the message that the choice of a lawyer by a person under investigation is exclusive as to preclude other equally competent and independent attorneys from handling the defense. Otherwise, the tempo of custodial investigation would be solely in the hands of the accused who can impede, nay, obstruct, the progress of the interrogation by simply selecting a lawyer who, for one reason or another, is not available to protect his interest."
• "Regardless of the number of killings or deaths that occurred as a consequence of the kidnapping, the appropriate denomination of the crime should be the special complex crime of kidnapping for ransom with homicide."

• People v. Mateo — Followed. Established the procedural rule that cases imposing the death penalty must be elevated to the Court of Appeals for automatic review before being forwarded to the Supreme Court.
• People v. Barredo — Followed. Held that seemingly illogical behavior by criminals, such as removing masks or failing to cover their faces in front of victims, does not automatically render a witness's testimony incredible if the trial court finds it truthful.
• People v. Fabro — Followed. Defined the requisites for a competent and independent counsel, stating that counsel cannot be a special counsel, public or private prosecutor, counsel of the police, or a municipal attorney whose interest is adverse to the accused.
• People v. Alvarez and People v. Encipido — Followed. Laid down the doctrine that interlocking extrajudicial confessions are admissible as circumstantial evidence against co-accused to establish the probability of their participation in the crime.
• People v. Quiachon — Followed. Ruled that the award of civil indemnity of ₱75,000.00 per death is proper where qualifying circumstances warranting the death penalty attended the commission of the offense, regardless of the prohibition on the actual imposition of the death penalty under R.A. No. 9346.

• Article 267, Revised Penal Code — Defines and penalizes the crime of kidnapping, especially qualifying the offense when the motive is to extort ransom or when the victim is killed, raped, or subjected to torture or dehumanizing acts as a consequence. Applied as the substantive basis for convicting the appellants of the special complex crime.
• Article III, Section 12, 1987 Constitution — Guarantees the right of a person under investigation to remain silent and to have competent and independent counsel, preferably of their own choice, and prohibits the use of torture or coercion to obtain confessions. Applied to uphold the admissibility of the extrajudicial confessions, as the PAOCTF complied with the mandated safeguards.
• Republic Act No. 7659 — Imposed the death penalty for kidnapping for ransom. Applied by the trial court originally, but the imposition was subsequently prohibited by R.A. No. 9346.
• Republic Act No. 9346 — Prohibits the imposition of the death penalty in the Philippines. Applied to reduce the penalty from death to reclusion perpetua without the possibility of parole.
• Articles 2217, 2219, 2223, and 2229, Civil Code — Govern the award of moral and exemplary damages. Applied to justify the awards of moral damages for illegal detention and exemplary damages due to the presence of qualifying circumstances.

Ynares-Santiago, Carpio, Corona, and Peralta.