Primary Holding

The Supreme Court affirmed that police officers can be held liable for kidnapping when they act in their private capacity rather than in furtherance of official functions, upholding the conviction of PO1 Trestiza and his co-accused for kidnapping for ransom.

Facts

• 1. Yu and Navarro were at Where Else Disco around 1:00 AM on November 7, 2002
• 2. Upon leaving, Navarro was accosted by armed men including Pineda whom she knew as her sister's "kumpare"
• 3. Yu was "sandwiched" by Trestiza and Manrique and forced into a Mitsubishi Adventure
• 4. The victims were driven around, threatened, and demanded ₱1,000,000 for their release
• 5. They were released after paying ₱180,000 through Yu's friends
• 6. The accused were later arrested through an entrapment operation

Arguments of the Petitioners

• 1. Trestiza was merely a driver and not part of the conspiracy
• 2. The operation was a legitimate PDEA drug bust
• 3. His warrantless arrest was illegal
• 4. Yu's later arrest for drugs in 2011 affects his credibility as a witness
• 5. The evidence was insufficient to support conviction

Arguments of the Respondents

• 1. Trestiza actively participated in the kidnapping beyond just driving
• 2. The alleged drug operation lacked proper documentation
• 3. Trestiza waived objection to his warrantless arrest
• 4. Yu's subsequent arrest is irrelevant to the kidnapping case

Issues

• 1. Whether police officers can be held liable for kidnapping
• 2. Whether Trestiza's warrantless arrest was valid
• 3. Whether there was conspiracy among the accused
• 4. Whether the operation was a legitimate police action

Ruling

• 1. The Supreme Court affirmed the conviction with modifications on damages
• 2. Police officers can be liable for kidnapping when acting in private capacity
• 3. Trestiza waived objection to his warrantless arrest
• 4. Evidence showed conspiracy among accused
• 5. The alleged drug operation lacked credible documentation

Doctrines

• 1. Police Officer Liability: Police officers can be held liable for kidnapping when acting outside official functions
• 2. Warrantless Arrest Objection: Must be raised before entering plea
• 3. Conspiracy Theory: May be proved through coordinated actions showing common design
• 4. Credibility of Witnesses: Trial court's assessment given great weight

Precedents Cited

• 1. People v. Santiano (1998) - Established police officer liability for kidnapping
• 2. People v. Manlulu (1994) - On warrantless arrest validity
• 3. People v. Pagalasan (2003) - On conspiracy through coordinated actions

Statutory and Constitutional Provisions

• 1. rticle 267, Revised Penal Code - Crime of Kidnapping
• 2. Section 5, Rule 113, Rules of Criminal Procedure - Warrantless arrests
• 3. Republic Act No. 7659 - Death penalty for kidnapping with ransom