In a kidnapping for ransom case, the Supreme Court affirmed the conviction of the accused, emphasizing the importance of reliable witness identification and the assessment of credibility by the trial judge. The court underscored that inconsistencies on minor details do not impair the credibility of witnesses, but rather strengthen it, discounting the possibility of rehearsed testimonies. The case reinforces the principle that positive identification, when consistent and categorical, holds significant weight in the conviction of the accused, especially when coupled with other corroborating evidence.

Unraveling a Web of Deceit: Can New Evidence Overturn a Kidnapping Conviction?

The case of *People of the Philippines vs. Roderick Licayan, Roberto Lara, and Rogelio “Noel” Delos Reyes* revolves around the kidnapping of Joseph Tomas Co and Linda Manaysay back in August 1998. Initially, Roderick Licayan and Roberto Lara were convicted and sentenced to death, a decision affirmed by the Supreme Court. However, prior to their scheduled execution, two other co-accused, Pedro Mabansag and Rogelio Delos Reyes, were apprehended. This led to a motion to reopen the case, resulting in a retrial and the subsequent arrest and trial of Delos Reyes.

The Supreme Court, in a rare move, allowed the reopening of the case to consider new evidence. This decision underscores the court’s commitment to ensuring justice, even when it requires revisiting final judgments. The central question became whether the new evidence presented by the accused-appellants, particularly regarding the reliability of witness identification and the testimonies of newly apprehended co-accused, warranted a reversal of the original conviction.

During the retrial, the defense focused on challenging the reliability of the identification made by the victims, Joseph Tomas Co and Linda Manaysay. They argued that Co’s identification of Licayan and Lara was inconsistent and unreliable, particularly regarding the pointing of their feet during the police line-up. However, the court noted that Co had positively identified Licayan and Lara through their faces, and the additional detail of their feet only served to reinforce his certainty. The inconsistencies pointed out by the defense were deemed minor and did not detract from the overall credibility of Co’s testimony. The trial court emphasized Co’s testimony as “very clear, positive and straightforward.”

Delos Reyes, on the other hand, invoked the exempting circumstance of uncontrollable fear, claiming that he was forced to guard the victims at gunpoint. Article 12 of the Revised Penal Code discusses circumstances that exempt from criminal liability, stating:

Art. 12. Circumstances which exempt from criminal liability. – The following are exempt from criminal liability:

x x x x

5. Any person who act under the compulsion of irresistible force.

The court, however, found his testimony to be inconsistent and incredible. His claims of being threatened and forced to participate were contradicted by his own actions and statements. The court noted his demeanor during the trial, stating that he was “obviously lying through his teeth.” As ruled in *People vs. Dansal*, the accused must show they acted without will and against their will. The duress must be imminent and impending to induce a well-grounded apprehension of death or serious bodily harm if the act is not done.

The Supreme Court emphasized the importance of the trial judge’s assessment of witness credibility. The judge had the opportunity to observe the witnesses’ demeanor, assess their truthfulness, and weigh the evidence presented. This firsthand observation is crucial in determining the veracity of testimonies and arriving at a just decision. The appellate court did not err when it relied on the doctrine that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge.

Regarding the new evidence presented by Mabansag and Delos Reyes, the court found it to be unpersuasive. Mabansag denied any involvement in the kidnapping, while Delos Reyes claimed he was merely forced to guard the victims. These statements were inconsistent with the victims’ testimonies and failed to exonerate Licayan and Lara. Furthermore, the testimonies of Lara’s co-workers, attempting to establish an alibi, were insufficient to prove that it was physically impossible for him to be at the scene of the crime.

The court underscored the legal standard for alibi, holding that for alibi to prosper, it is not enough to prove that the accused was somewhere else when the crime was committed. The accused must also demonstrate that it was physically impossible for him to have been at the scene of the crime at the time of its commission. In this case, the proximity of Lara’s workplace to the crime scene and his presence in the same area where the victims escaped weakened his alibi.

Ultimately, the Supreme Court affirmed the conviction of Licayan, Lara, and Delos Reyes, finding their guilt proven beyond reasonable doubt. While the death penalty was no longer applicable due to Republic Act No. 9346, which prohibited its imposition, the court upheld the penalty of *reclusion perpetua*. The court also modified the amount of damages to be awarded to the victims, increasing it to P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages for each victim. These damages aimed to provide compensation for the harm suffered by the victims and to serve as a deterrent against future crimes.

This case highlights the complexities of criminal trials, the importance of witness credibility, and the challenges of presenting new evidence to overturn a conviction. It also underscores the court’s commitment to upholding justice while adapting to changes in the law and considering mitigating circumstances. The decision serves as a reminder of the stringent standards of proof required in criminal cases and the weight given to the trial judge’s assessment of witness credibility.

FAQs

What was the key issue in this case?	The key issue was whether the new evidence presented by the accused warranted a reversal of their conviction for kidnapping for ransom. This included challenging the reliability of witness identification and considering the testimonies of newly apprehended co-accused.
What is the significance of witness credibility in this case?	Witness credibility was crucial. The court heavily relied on the trial judge’s assessment of the witnesses’ demeanor and truthfulness. Inconsistencies on minor details didn’t impair credibility but strengthened it, discounting the possibility of rehearsed testimonies.
What is the exempting circumstance of uncontrollable fear?	The exempting circumstance of uncontrollable fear, under Article 12 of the Revised Penal Code, can exempt a person from criminal liability if they acted under the compulsion of an irresistible force, reducing them to a mere instrument without will. This requires clear and convincing evidence that the force was present, imminent, and impending, inducing a well-grounded apprehension of death or serious bodily harm.
What is required for an alibi to be successful?	For an alibi to be successful, the accused must prove not only that they were somewhere else when the crime was committed but also that it was physically impossible for them to have been at the scene of the crime at the time of its commission. The defense must show it was physically impossible for them to be at the crime scene.
Why was the death penalty not imposed in this case?	The death penalty was not imposed because Republic Act No. 9346, which prohibits the imposition of the death penalty in the Philippines, was enacted during the proceedings. The accused were instead sentenced to reclusion perpetua.
What damages were awarded to the victims in this case?	The Supreme Court modified the damages awarded to the victims, increasing it to P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages for each victim. These damages were intended to compensate the victims for the harm they suffered and deter future crimes.
How did the court view the new testimonies in this case?	The new testimonies presented by the co-accused Mabansag and Delos Reyes were viewed with skepticism. The court found their statements to be inconsistent and self-serving and did not find them sufficient to exonerate the accused.
Why did the Supreme Court allow the reopening of the case?	The Supreme Court allowed the reopening of the case to ensure justice was served. Despite the finality of the initial judgment, new evidence emerged with the arrest of co-accused who were previously at-large. The court, recognizing its power to suspend its own rules, deemed it necessary to consider the new evidence.

This case underscores the Philippine judicial system’s commitment to ensuring a fair trial even when faced with complex legal issues and potentially conflicting evidence. The ruling emphasizes the vital role of the trial judge in evaluating witness credibility and the high bar for successfully overturning a conviction based on new evidence. It serves as a reminder of the importance of reliable witness identification and the enduring quest for justice in the Philippine legal system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People vs. Licayan, G.R. No. 203961, July 29, 2015