Primary Holding

The Court held that when a complex crime has been charged in an information and the evidence fails to support the charge on one of the component offenses, the defendant can still be separately convicted of the other offense when properly established.

Facts

• 1. On May 13, 1993, Ramon John Dy Kow Jr. and his live-in partner were arrested by appellants Sandigan and Pillueta for alleged marijuana possession.
• 2. After being warned not to contact a lawyer and being told "it is only a matter of P10,000.00," they were detained at Naga City Jail when they proceeded to get legal representation anyway.
• 3. In July 1993, appellant Santiano was detained in the same cell as the victim and was allegedly mauled by inmates including the victim.
• 4. On December 27, 1993, around 6:00 PM, the victim obtained permission to buy food outside the jail. While emerging from the PNP store, he was accosted by Sandigan and Santiano.
• 5. The victim was taken to the NARCOM office where he was mauled by Santiano for about 15 minutes while Pillueta acted as lookout.
• 6. The victim was then transported via trimobile driven by Chanco toward Palestina, Pili, Camarines Sur.
• 7. The following morning, the victim's body was discovered with multiple gunshot wounds.

Arguments of the Petitioners

• 1. The prosecution argued that the accused conspired to kidnap and kill the victim, establishing all elements of kidnapping under Article 267.
• 2. They presented witnesses who saw the actual abduction, mauling, and transport of the victim.
• 3. The prosecution emphasized that the detention was not merely incidental to murder but a separate criminal act.

Arguments of the Respondents

• 1. The prosecution argued that the accused conspired to kidnap and kill the victim, establishing all elements of kidnapping under Article 267.
• 2. They presented witnesses who saw the actual abduction, mauling, and transport of the victim.
• 3. The prosecution emphasized that the detention was not merely incidental to murder but a separate criminal act.

Issues

• 1. Whether the information sufficiently charged kidnapping with murder as a complex crime.
• 2. Whether appellants can be convicted of kidnapping when evidence fails to establish murder.
• 3. Whether the acts constituted kidnapping or were merely incidental to murder.

Ruling

• 1. The Supreme Court affirmed the RTC decision
• 2. The information sufficiently charged kidnapping with murder, properly apprising the accused of the charges.
• 3. Evidence established the elements of kidnapping beyond reasonable doubt.
• 4. The kidnapping was not absorbed by murder as the detention was not proven to be solely for the purpose of killing the victim.
• 5. The accused acted in conspiracy, making all equally liable.

Doctrines

• 1. Sufficiency of Information: An information is sufficient if it states the statutory designation of the offense and the acts constituting it.
• 2. Complex Crime Conviction: When charged with a complex crime, conviction for one component offense is possible despite failure of evidence on the other component.
• 3. Non-absorption Doctrine: Kidnapping is not absorbed by murder when detention is not proven to be solely for the purpose of killing.

Precedents Cited

• 1. United States vs. Lahoylahoy and Madanlog (38 Phil. 330): Established that conviction on one offense in a complex crime is legally feasible despite failure of evidence on other charges.
• 2. Sta. Rita vs. Court of Appeals (247 SCRA 484): On sufficiency of information requirements.
• 3. U.S. vs. Lampano (13 Phil. 409, 413): Regarding defects in information being cured by evidence.

Statutory and Constitutional Provisions

• 1. Article 267, Revised Penal Code (Pre-RA 7659): Defining and penalizing kidnapping and serious illegal detention
• 2. Article 248, Revised Penal Code: On murder
• 3. Republic Act No. 7659: Amending Article 267 of the Revised Penal Code