FACTS:

The case involves the kidnapping of Enrico Paulo Agra, an 8-year-old boy. The accused in the case are Pablito Domasian and Samson Tan. Domasian pretended to need Enrico's help and took him to several public places. However, Enrico became apprehensive and started to cry when Domasian took him far away from the hospital where he was going. Enrico's cries aroused suspicion from a tricycle driver, Alexander Grate, who asked Domasian about his relationship with the boy. Domasian claimed they were brothers, but Grate found this suspicious due to their physical differences and age gap. Grate reported the matter to barangay tanods. Domasian attempted to escape, leaving Enrico behind. Enrico was later found by his parents. A ransom note demanding P1 million was received by Enrico's father, Dr. Enrique Agra. The handwriting in the note was eventually determined to belong to Dr. Samson Tan. Domasian and Tan were charged with the crime of kidnapping with serious illegal detention. The trial court found both accused guilty and sentenced them to reclusion perpetua. The accused-appellants denied any participation in the incident and challenged the credibility of the prosecution witnesses.

ISSUES:

1. Whether the accused-appellants can be convicted of the crime of kidnaping with serious illegal detention.

2. Whether there is sufficient evidence to prove the guilt of the accused-appellants beyond reasonable doubt.

3. Whether the credible testimonies of the witnesses outweigh the alibi and denial of the accused-appellants.

4. Whether there is sufficient basis to find a conspiracy between the accused-appellants.

RULING:

1. The accused-appellants can be convicted of the crime of kidnaping with serious illegal detention. The Court held that the detention of the victim, Enrico, constituted serious illegal detention as it involved the use of force and intimidation. The fact that Enrico was transported to several public places during the detention does not negate the crime, as the important question is why the accused-appellant detained Enrico in the first place after pretending to need his help.

2. There is sufficient evidence to prove the guilt of the accused-appellants beyond reasonable doubt. The positive identification of the accused-appellants by Enrico, as well as the testimony of other witnesses, establishes their participation in the crime. The trial court's assessment of the credibility of witnesses is given deference by the appellate court.

3. The credible testimonies of the witnesses outweigh the alibi and denial of the accused-appellants. The Court found the testimonies of Enrico, his classmate Tirso, and tricycle driver Grate to be credible, as their identification of the accused-appellants was consistent and had no ill motive. The defense's witnesses, on the other hand, were not considered disinterested, as one of them admitted to knowing one of the accused-appellants for three years.

4. There is sufficient basis to find a conspiracy between the accused-appellants. The Court held that the evidence presented, particularly the simultaneous actions of the accused-appellants in detaining Enrico, indicated the existence of a conspiracy. The defense failed to provide any explanation or evidence that would undermine this finding.

PRINCIPLES:

• The credibility of witnesses is primarily assessed by the trial judge, whose findings are accorded great respect by the appellate court due to the judge's opportunity to directly observe the demeanor of the witnesses.

• Positive identification by credible witnesses can sufficiently establish the guilt of the accused beyond reasonable doubt.

• Alibi and denial as defenses must be supported by strong, clear, and convincing evidence to overcome the positive identification and testimonies of credible witnesses.

• Conspiracy may be inferred from the simultaneous actions and coordination of the accused in committing the crime.